Monitoring change, externally and internally, and within the company’s operations, requires special emphasis in evaluating its impact on the business, the financial statements and the required disclosures. The Disclosure Committee of Key Energy Services, Inc. (the “Company”) has developed a quarterly and/or annually roll-up certification process that requires certain officers, managers, and employees across the organization to certify to matters regarding the flow of material information upwards to senior management. This process will enable the Disclosure Committee and the Company’s certifying officers, the CEO and CFO, to address new issues and developments, on a timely basis, that require action and possible disclosure.
In determining whether all “material” information is included in the disclosures to management, you should consider what information related to your business unit or area of responsibility a reasonable stockholder would find important in determining whether to buy, hold or sell the Company’s stock (or other securities).
Your responses to the questions in the certification will form the basis of your certification, for your area of responsibility. It will facilitate the process of complying with the SEC requirements regarding Disclosure Controls and Procedures.
Please complete the enclosed Third Quarter 2017 Disclosure & Controls Certification for your area of responsibility by responding to each question, signing and returning to Michelle Perry no later than Friday, October 20, 2017. Your certification does not require you to review the Form 10-Q. However, your certification will enable the CEO and CFO to certify as to the fairness of the information presented in these public reports.
The Disclosure Committee and senior management will be responsible for reviewing the Form 10-Q and then completing their Disclosure & Controls Certifications as well by no later than November 2, 2017. The Disclosure Committee and senior management will review your certificates in conjunction with completing their certifications.
Disclosure Committee Meeting:
The Disclosure Committee will meet to review the results of the Disclosure & Controls Certifications. Upon completion of their review, the CEO and CFO will complete the quarterly certifications as required by Section 302 of the Sarbanes Oxley Act of 2002. The certifications will provide assurance of the completeness and accuracy of the public reports filed by the Company and the nature and effectiveness of internal controls supporting the quality of information included in such reports.