7.08 The internal control paragraph refers to 'those criteria' and '[wording masked]', which the Annual Report never identifies
UK Company A · a UK-listed medical technology group · Drafting slip
In brief
The internal control review says management concluded the controls [wording masked]', but the section never says which criteria (framework) were used. It then says the auditor audited the financial statements '[wording masked]', a phrase that belongs to a numbered filing form, not to the Annual Report. The same two phrases appear in the 2025 report.
The evidence, as filed
Screenshot withheld to protect the company’s identity: Annual Report 2024, page 82; Annual Report 2025, page 82. Their wording or layout could lead back to the company even with names and figures masked; the evidence list below records what each page shows.
What the report shows, and what the rule requires
| What the annual report shows | What the rule requires |
|---|---|
| What the annual report shows 2024 report p.82: '[wording masked]' and '[wording masked]'. 2025 report p.82: the same two phrases. | What the rule requires Name the framework used (for example the internal control framework against which management assessed effectiveness) and replace 'required by this item' with a reference that makes sense in the Annual Report, or delete it. |
Why it matters
Readers cannot tell against which framework management judged the controls effective, and the wording signals text carried across from another document without editing.
Exposure
Drafting point; no statutory consequence.
Our workings
the bullet on p.82 of the 2024 report ends '[wording masked]'; the preceding text on pp.80-82 describes the control framework but does not name a set of criteria. The next paragraph refers to '[wording masked]'.
No conclusion or figure changes, so this is a drafting point.
Management’s best defence, and our reply
The company could say the paragraph mirrors its US filing on purpose so that both documents say the same thing, and that the framework is named in that filing. That keeps the documents aligned but does not make the phrases meaningful in the Annual Report, which must be read on its own; a one-line edit fixes it.
The fix
- Replace with: 'Based on their assessment against [named framework], management concluded that, as at [date], the Group's internal control ... was effective. [audit firm] [wording masked] this Annual Report.'
Evidence relied on
| # | What it shows | Type | Where |
|---|---|---|---|
| 1 | 2024 report: management's conclusion refers to 'those criteria' with no criteria named | Document | Annual Report 2024, page 82 |
| 2 | 2024 report: refers to 'this item', a numbered-form phrase | Document | Annual Report 2024, page 82 |
| 3 | 2025 report repeats the same wording | Document | Annual Report 2025, page 82 |
| 4 | 2025 report repeats 'required by this item' | Document | Annual Report 2025, page 82 |
| 5 | the 2025 report repeats [wording masked]' wording, which refers to no item in the Annual Report | Document | Annual Report 2025, page 82 |
| 6 | the 2025 report repeats 'based on those criteria' with no criteria named anywhere in the report | Document | Annual Report 2025, page 82 |
Prepared by Pramanex from the company’s published annual reports, without the company’s involvement, to show how an annual report review reads. The company is not named, and nothing on this page is a statement about any identifiable company. Observations are not an audit, review or other assurance engagement, and not legal advice. A regulator-style question is a question, not a conclusion.
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