CL 96
19 May 2006
Kil-Woo Lee
Project Manager
International Accounting Standards Board
30 Cannon Street
London EC4M 6XH
United Kingdom
CommentLetters@iasb.org
Re: ED 8 Operating Segments
We are pleased to provide our comments on the exposure draft ED8 Operating Segments.
We believe the draft IFRS is likely to bring improvements in the relevance, reliability and
timeliness of segment reporting while reducing the cost of external reporting. We support
the use of the management approach because it gives the users the opportunity to view the
information from the same perspective as the management.
However, we do not support the proposal to require the use of management’s own internal
reporting data, even if they are non IFRS compliant. As a matter of fact, we consider that
introducing different measurement basis goes against the principle of comparability and
hence compels users to analyse two sets of evaluation principles.
The market has reached a point where investors and users have just begun to consider the
information produced through the application of the existing version of IFRSs as relevant
and comparable; we believe it is not appropriate to introduce a deviation from the rule.
You will find enclosed detailed answers to the questions asked by the exposure draft in the
appendix to this letter. Should you have any questions regarding our comments, please do
not hesitate to contact us.
Yours sincerely
Gérard Gil
Chief Accounting Officer
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APPENDIX
ED 8: Operating Segments
Question 1—Adoption of the management approach in SFAS 131
Question 1—The draft IFRS adopts the management approach to segment reporting set out
in SFAS 131 Disclosures about Segments of an Enterprise and Related Information issued
by the US Financial Accounting Standards Board.
Is this approach to segment reporting appropriate? If not, why not? What, if any,
alternative approach would you propose?
We agree that the management approach is an appropriate approach for segment reporting
because it provides the most relevant and consistent information to users insofar as it
enables users to view the information from the same perspective as the management.
On the other hand, we do not support the proposal to require the use of management’s own
internal reporting data, even if they are not IFRS compliant.

We believe that using internal non IFRS compliant reporting data goes against the
principle of comparability that stays in the framework as an objective of financial
statements. Two entities operating in the same business activities, in the same
economic environment should not be allowed to measure and to present data not
evaluated on the same basis although they both present IFRS financial statements.

It will be difficult for users to understand and interpret information when significant
differences exist between internal and external reporting data even if this present
draft provides for disclosures in order to explain the basis of measurement and the
elements of reconciliation.
Question 2—Divergence from SFAS 131
Question 2— Do you think that the draft IFRS should depart from the management
approach in SFAS 131 by setting requirements for
(a) the measurement of specified items or
(b) the disclosure of specified amounts that might otherwise not be given?
If so, identify the requirements you would add and indicate what you see as the relative
costs and benefits of any such requirements.
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As explained in our answer to question 1, we think it is important that IFRS measures are
used to prepare segment information.
Otherwise, we believe that the disclosure of information included in the existing internal
reporting provides users with all information, and only information, useful to them. We
therefore disagree with requiring additional disclosures.
Questions 3—Scope of the standard
Question 3—The existing standard IAS 14 requires entities whose equity or debt securities
are publicly traded and entities that are in the process of issuing equity or debt securities in
public securities markets to disclose segment information. The draft IFRS extends the
scope to include also entities that hold assets in a fiduciary capacity for a broad group of
outsiders.
Do you agree with the scope of the draft IFRS? If not, why not?
We do not think that the exposure draft explains the proposed scope extension of segment
reporting.
As explained in the basis for conclusions, the definition of publicly accountable entities is
to be finalised as part of the IFRS for SMEs project. We therefore recommend that no
decision is made prior to the finalisation of the IASB’s definition of a publicly accountable
entity.
Questions 4—Level of reconciliations
Question 4— The draft IFRS requires an entity to provide, for specified items,
reconciliations of total reportable segment amounts to amounts recognised by the entity in
accordance with IFRSs. It does not require such reconciliations for individual reportable
segments.
Do you agree with the level of reconciliations required in the draft IFRS? If not, indicate
what you see as the relative costs and benefits of any other level of reconciliation.
Since we support the use of IFRS compliant data for segment reporting, we do not really
have to define the level of reconciliation.
Questions 5—Geographical information about assets
Question 5— The draft IFRS requires an entity to disclose geographical information about
non-current assets excluding specified items.
It does not require disclosure of
geographical information about total assets.
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Do you agree with the requirement to disclose geographical information about non-current
assets excluding specified items? If not, for which assets would you require geographical
information to be given?
Yes, we agree.
Questions 6—Consequential amendments to IAS 34 Interim Financial Reporting
Question 6— The draft IFRS requires an entity to disclose more segment information in
interim financial reports than is currently required, including a reconciliation of the total
of the reportable segments’ measures of profit or loss to the entity’s profit or loss.
Do you agree with the consequential amendments made to IAS 34? If not, why not?
We agree with the consequential amendments made to IAS 34.
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