ITEM 9. CHANgEs IN ANd dIsAgrEEMENTs wITH ACCOuNTANTs ON ACCOuNTINg ANd FINANCIAl dIsClOsurE ITEM 9A. CONTrOls ANd PrOCEdurEs REPORT OF MaNaGEMENT ON INTERNal cONTROl OVER FINaNcIal REPORTING Not applicable. As of the end of the period covered by this report, the Company’s management carried out an evaluation, under the supervision and  with the participation of the Company’s principal executive officer and principal financial officer, of the effectiveness of the design and  operation of the Company’s disclosure controls and procedures as defined in Exchange Act Rule 13a-15(e). Based upon that evaluation,  the principal executive officer and principal financial officer concluded that the Company’s disclosure controls and procedures were  effective as of the end of the period covered by this report. There have been no changes during the Company’s fourth quarter of 2011 in the Company’s internal control over financial reporting that  have materially affected, or are reasonably likely to materially affect, the Company’s internal control over financial reporting. The management of The Timken Company is responsible for establishing and maintaining adequate internal control over financial  reporting for the Company. Timken’s internal control system was designed to provide reasonable assurance regarding the preparation  and fair presentation of published financial statements. Because of its inherent limitations, internal control over financial reporting may  not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that  controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures  may deteriorate. Timken management assessed the effectiveness of the Company’s internal control over financial reporting as of December 31, 2011.  In making this assessment, it used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission  (COSO). Based on this assessment under COSO’s “Internal Control-Integrated Framework,” management believes that, as of  December 31, 2011, Timken’s internal control over financial reporting is effective. On July 1, 2011, the Company acquired the assets of Philadelphia Gear, which now the Company operates as Timken Gears and  Services Inc. On October 3, 2011, the Company acquired Drives, which now the Company operates as Timken Drives LLC. As permitted  by SEC guidance, the scope of Timken’s evaluation of internal control over financial reporting as of December 31, 2011 did not include  the internal control over financial reporting of Timken Gears and Services Inc. and Timken Drives LLC. The results of Timken Gears and Services Inc. and Timken Drives LLC are included in the Company’s consolidated financial statements beginning July 1, 2011 and October 3, 2011, respectively. The total assets of Timken Gears and Services Inc. and Timken Drives LLC represented less than six  and three percent, respectively, of the Company’s total assets at December 31, 2011. Net sales of Timken Gears and Services Inc. and  Timken Drives LLC represented less than two and one percent, respectively, of the Company’s consolidated net sales for the year then ended and less than four and one percent, respectively, of net income for the year then ended. The Company will include Timken Gears and Services Inc. and Timken Drives LLC in the Company’s internal control over financial reporting assessment as of  December 31, 2012. Ernst & Young LLP, independent registered public accounting firm, has issued an audit report on our assessment of Timken’s internal  control over financial reporting as of December 31, 2011, which is presented below. CONTrOls,rEPOrTs ANd ExHIBITs 87$^{ }$ THE TIMKEN COMPANY