Denise Silva Ferreira Juvenal [email protected] Accountant Individual Commentary Rio de Janeiro / Brazil and Manuel Rejón Lopez [email protected] Accountant Granada / Spain Individual Commentary

Sir Hans Hoogervorst Chairman International Accounting Standards Board - IASB Trustees of The International Financial Reporting Standards - IFRS Foundation 30 Cannon Street, London EC4M 6XH, United Kingdom. Tel: +44 (0)20 7246 6410 Fax: +44 (0)20 7246 6411 Email: [email protected] Web: www.ifrs.org Email: [email protected]

November 16, 2012

We are Denise Juvenal and Manuel López are pleased to have the opportunity to comment on this consultation and we agree with this study of the Postimplementation Review: IFRS 8 Operating Segments Comments to of the IASB. Questions: Question 1 Are you comparing IFRS 8 with IAS 14 or with a different, earlier segmentreporting Standard that is specific to your jurisdiction? In providing this information, please tell us: (a) what your current job title is; (b) what your principal jurisdiction is; and (c) whether your jurisdiction or company is a recent adopter of IFRSs. If you work in a non-IFRS environment your input is still useful to us—but we would like to know about your current reporting of operating segments so that we can assess your information in that context. 1

Denise Silva Ferreira Juvenal – Accountant – Brazil – Rio de Janeiro – phone: 552193493961 - email: [email protected] Manuel Rejón López - Accountant – Spain – Granada – phone: 34615190371 - email: [email protected] Question 2 What is your experience of the effect of the IASB’s decision to identify and report segments using the management perspective? Investors: please focus on whether our initial assessment—that the management perspective would allow you to better understand the business— was correct. What effect has IFRS 8 had on your ability to understand the business and to predict results? Preparers: please include information about whether your reporting of operating segments changed when you applied IFRS 8. If it did, what effect did that change have on the efficiency of your reporting processes and your ability to communicate with investors? We are accountants that research IFRS 8, attend some discussion papers about auditing and financial reporting elaborated for regulators and understand that this process can be improve high quality, effectiveness and development of the financial reporting, for this we are comments as individual opinion. The operating segments are integrated with link between the business operations and the main components of the financial statements. These decisions were: a. to identify segments based on the management approach; b. to measure disclosed line items on the basis used for internal reporting; and c. to disclose only those line items regularly reviewed by the chief operating decision maker1 We understand that is very important the organization understand the process and makes investment one person that knowledge the process and activity for management contact for investors, principally for attend many facts that happened in this moment in relation international standards, finances and valuation. We observed that the implications for consistency with management´s discussion and analysis in annual reports that has relation with some discussed, that we suggest, if board agree observed the results about reporting, as for example: 

International Federation on Accountants – IFAC (Auditor Reporting2 and Evaluating and Improving Internal Control3,

1

http://www.ifrs.org/Current-Projects/IASB-Projects/PIR/IFRS-8/summaries/Pages/IASBJune2012.aspx

2



International Integrated Reporting Council – IIRC (Integrated Reporting)4,



Committee of Sponsoring Organizations of the Treadway Commission – COSO (Internal Control Over External Financial Reporting)5,



International Accounting Standards Board – IASB with Due process handbook6.

We think that is need to integrated every informations a system for example, the use XBRL as tool, that will be attend internal control, international standards, international auditing and principally the reporting would have same characteristics and most of important informations that the organizations need to demonstrate. Question 3 How has the use of non-IFRS measurements affected the reporting of operating segments? Investors: please comment on the effect that the use of non-IFRS measurements has had on your ability to understand the operating risks involved in managing a specific business and the operating performance of that business. It would be particularly helpful if you can provide examples from published financial statements to illustrate your observations and enable us to understand the effects that you describe. Preparers: it would be helpful if you could provide information about whether you changed your measurement basis for operating segment information on the application of IFRS 8 and, if so, what effect this has had on your ability to communicate information about operating risks and performance with investors and other users of your financial statements. We think that operating segments into reportable segments the reporting elaborated for organizations for directors or board, partner, is more useful for to take decisions. But, we think that many reporting that elaborated for managers need to be similar the Practice Statement elaborated for IASB, or most of informations about finance situation of the organizations are described in the notes of Financial Reporting. We understand that one objective, transparency; clearly reporting can be attending operating segments IFRS 8, if decision don´t make application of IFRS will be very difficult for identify transparency, responsibility, social, clearly and objective of this standards. 2

http://www.ifac.org/publications-resources/improving-auditor-s-report https://www.ifac.org/publications-resources/evaluating-and-improving-internal-control-organizations-0 4 http://www.theiirc.org/wp-content/uploads/Yearbook_2012/sources/indexPop.htm 5 http://www.ic.coso.org/default.aspx 6 http://www.ifrs.org/DPOC/DueProcessHandbook/Pages/Handbookand.aspx 3

3

Question 4 How has the requirement to use internally-reported line items affected financial reporting? Investors: please focus on how the reported line items that you use have changed. Please also comment on which line items are/would be most useful to you, and why, and whether you are receiving these. Preparers: please provide information about any changes in reported line items that resulted from the application of IFRS 8. We think that this information is very important for industries that depend of the aspects related of operation of the organizations, is very important the board contact information of this process in the local regulators. We think that revenues is very difficult, because impact in taxes and fiscal laws in the countries, that in some times need to be more explain in the reporting the details, we don´t know. We think that operating segment disclosures to those competitors in relation the management of activities in the organization, the knowledge of management with experience in others areas for example finances and business administration. For example, the IFAC has good project about management, if the board agree, we suggest evaluating and improving organizations.7 Question 5 How have the disclosures required by IFRS 8 affected you in your role? Investors:

please

provide

examples from

published operating segment

information to illustrate your assessment of the disclosures relating to operating segments. Do you now receive better information that helps you to understand the company’s business? Please also comment on the specific disclosure requirements of IFRS 8—for example, those relating to the identification and aggregation of operating segments; the types of goods and services attributed to reportable segments; and the reconciliations that are required. It would also be useful to indicate whether you regularly request other types of segment disclosures. Preparers: please consider whether operating segment disclosures are more or less burdensome when based on information prepared in accordance with your own internal reporting requirements. If any requirements are burdensome, please provide details of those disclosures and explain why they are costly or time-consuming to prepare. Do you think that the information you present now 7

https://www.ifac.org/publications-resources/evaluating-and-improving-governance-organizations

4

about operating segments conveys better information to investors and shareholders? It would be useful to indicate whether you regularly report any segment information in addition to that required by IFRS 8. We think that the activity of the organization in the implementation can be more complex and difficult, because the items related in IFRS 8 has more impact with legal tax or fiscal local or not, in some jurisdictions.

Question 6 How were you affected by the implementation of IFRS 8? Preparers: in answering this question please focus on whether you incurred significant unexpected costs, either as a one-time expense when implementing the Standard or as a recurring cost at each reporting cycle. If you did incur unexpected costs, please explain what these were and in what way they were required to comply with IFRS 8. In addition, we would like to know what practical difficulties you encountered, if any, when applying IFRS 8. Did you find that IFRS 8 is clear about all aspects of the requirements, such as the identification of operating segments, aggregation of segments and the nature of the CODM? If IFRS 8 is not clear, please provide details of your experience. Investors: please focus on whether the way in which you use financial reports has changed as a result of applying IFRS 8. Please explain to us what that effect was and the consequences of any changes to how you analyse data or predict results. We suggest for the board consult local regulators for understand the process and activities of organizations for production and services and the impact of legal systems internal or external in this activities. We think that implementation of IFRS 8 need to be training in the organizations elaborated for local regulators. We understand that is very important training in many areas related of the same subject for attend the news discussions and possible new modifications in the international standards as for example: Conceptual Framework 8 in Financial Accounting Standards Board - FASB, The definitions about derivatives9 elaborated for European Securities and Markets Authority - ESMA, Code ethics10 for International

8 9

http://www.fasb.org/jsp/FASB/Page/SectionPage&cid=1175801893139 http://www.esma.europa.eu/news/ESMA-defines-standards-derivatives-and-CCPs?t=326&o=home http://www.ifac.org/publications-resources/proposed-change-definition-those-charged-governance

10

5

Federation on Accountants - IFAC and Audit for financial instruments elaborated 11 for Financial Reporting Council - FRC.

Thank you for opportunity for comments this proposal; if you have questions do not hesitate contact to us, [email protected] and [email protected].

Yours, Denise Silva Ferreira Juvenal [email protected] +552193493961 and Manuel Rejón Lopez [email protected] +34615190371

11

http://www.frc.org.uk/News-and-Events/FRC-Press/Press/2012/October/FRC-consults-on-updated-guidance-for-the-audit-of.aspx

6