As of March 9, 2009
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• Eagle Rock maintains extensive internal controls to ensure the proper execution, valuation and
reporting of derivative transactions.
• As part of these controls, Eagle Rock has segregated various duties:
– Hedging recommendation - Risk Management Committee
– Trade execution - SVP, Corporate Development
– Trade witnessing and entry - 3rd party risk management consultant
– Valuation - VP, Financial Reporting
– Settlement - VP, Investor Relations and Treasurer
• Eagle Rock uses the Kiodex system to record and value derivative positions.
• In addition, Eagle Rock’s internal and external auditors routinely test various hedging-related
controls.
• The Board of Directors establishes the maximum hedging levels and the maximum amount of
hedging that can be conducted in a given quarter. These limits can be exceeded with Board
approval, however.
• The Audit Committee of the Board of Directors and the full Board receive a hedging update each
quarter at their regular meetings.
• In practice, all large hedging transactions are discussed with the Board of Directors, even if the
Risk Management Policy does not specifically require it.
Hedging Processes and Controls
Internal Controls