2015 ESOS Guidelines Chapter 1 ? Who Qualifies

The base criteria are any UK undertaking that employs more than 250 people and/or has a turnover in excess of ?50 million and/or has a balance sheet total greater than ?43 million. There is little point in attempting to separate off high polluting areas. If one corporate group qualifies for ESOS, then all the others are obligated to take part too. The sterling equivalents of ?38,937,777 and ?33,486,489 were set on 31 December 2014 and apply to the first compliance period.

Representatives of Overseas Entities

UK registered branches of foreign entities are treated as if fully UK owned. They also have to sign up if any overseas corporate element meets the threshold no matter where in the world. The deciding factor is common ownership throughout the ESOS system. ecoVaro appreciates this. We have seen European companies dumping pollution in under-regulated countries for far too long.

Generic Undertakings that Could Comply

The common factor is energy consumption and the organisation’s type of work is irrelevant. The Environmental Agency has provided the following generic checklist of undertakings that could qualify:

Limited Companies Public Companies Trusts
Partnerships Private Equity Companies Limited Liability Partnerships
Unincorporated Associations Not-for-Profit Bodies Universities (Per Funding)

Organisations Close to Thresholds

Organisations that come close to, but do not quite meet the qualification threshold should cast their minds back to previous accounting periods, because ESOS considers current and previous years. The exact wording in the regulations states:

?Where, in any accounting period, an undertaking is a large undertaking (or a small or medium undertaking, as the case may be), it retains that status until it falls within the definition of a small or medium undertaking (or a large undertaking, as the case may be) for two consecutive accounting periods.?

Considering the ?50,000 penalty for not completing an assessment or making a false or misleading statement, it makes good sense for close misses to comply.

Joint Ventures and Participative Undertakings

If one element of a UK group qualifies for ESOS, then the others must follow suit with the highest one carrying responsibility. Franchisees are independent undertakings although they may collectively agree to participate. If trusts receive energy from a third party that must do an ESOS, then so must they. Private equity firms and private finance initiatives receive the same treatment as other enterprises. De-aggregations must be in writing following which separated ESOS accountability applies.

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Project Management

In a cutthroat market, where the competition is constantly on the attack to break into your market share, implementing a project-based system can give your organisation the necessary tools to be more efficient and agile.

However, rapidly changing consumer demands, technologies and other factors make it ever more difficult to generate a strategic advantage from projects, let alone develop one. Also since a large organisation can easily end up having to manage multiple projects at the same time, the new management paradigm can appear too complex.

What your company really needs is the expertise that can guide you starting from conception and planning, down through procurement and execution in order to maximise whatever resources you have. Each move must be well thought out so that there are clear goals and objectives as well as methods to achieve them.

Programme Management

Are you running multiple projects pointing to an overall strategic direction? Then you’ll need more than just a “scaled-up” version of project management to make sure every component’s work effort is well coordinated to achieve your enterprise’s desired outcomes.

Through our expertise in programme management, we’ll work with your stakeholders, executives and clients to achieve the following:

  • Design a well-articulated management structure and clearly define decision-making roles & responsibilities – This will ensure decisions are made rapidly with zero to minimal overlapping issues and to promote a unified, well-synchronised advance towards the common objective.
  • Set objectives then make sure they are met by guiding your key personnel in coordinating activities across projects.
  • Design or utilise existing financial models such that they adhere to your enterprise’s financial policies.
  • Develop procedures for reporting expenditures specific to the programme.
  • Establish the programme infrastructure, including
    • The appropriate technical environment and tools (e.g. hardware, software, communication, and other IT-related items)
    • IT staff and administrators
  • Evaluate your enterprise’s current IT architecture to determine whether it will suffice to achieve your objectives. If it doesn’t, propose options you can take to meet what is required.
  • Plan out activities that should take place in different levels in the organisation.
  • Implement a periodic review of the programme progress as well as of interim results to ensure everything is aligned with the strategic outcome.

Programme and Project Reviews

Whether we’ve helped you set up your programme or you did it on your own, time will come when you’ll need to know whether everything is going as planned. If it appears like the entire programme is going smoothly, chances are, something’s going awfully wrong somewhere. Remember, even the most well-planned projects and programmes are still under the mercy of unforeseen variables.

We’ve got highly specialised reviews for either projects or an entire programme. We’ll be able to provide you answers to questions like:

  • Are all projects aligned with the programme’s intended direction?
  • Are the people working on your projects as focused with the business rationale as they have been with meeting deadlines and utilising resources?
  • Where are your risks and exposures? How can they be remedied?
  • Is the project viable at all?

We understand how your staff would want to function normally as quickly as possible. Rest assured, our programme and project reviews are conducted swiftly and efficiently so that both interruptions and oversights are brought to a minimum.

After we’re done, you can expect a detailed quantitative assessment of your programme and/or projects’ status.

Basically, we’re not here to find mistakes; we’re here to help you find ways to correct them. If a project rescue is required, we’ll be the first to lend a hand.

Project Rescue

Believe it or not, many of our clients approached us not before or during their project’s planning stages. But rather, after having gone through sloppy execution, when they end up losing control. In other words, we’re usually at the receiving end of the distress signal, after they’ve punched the panic button.

While obviously this isn’t the ideal time to seek the aid of any expert because it means you’ve incurred unnecessary losses already, all is not yet lost. If the appropriate remedial actions are taken in a timely manner, you can still achieve highly acceptable end results.

In fact, in most of our experiences with project rescue operations, we’ve been able to put projects back on track – just the way the planners wanted them to be. We’ll also help you devise airtight strategies to prevent your project from going astray again.

At the end of our project rescue,

  • You’ll regain complete control
  • Milestones will be reached as planned
  • Requirements will be accomplished, and
  • The project will be realigned with ideal business directions

Project Governance Processes

Constructing a firm underlying structure is essential in any organisation. So before we’ll institute project management, we’ll do the following first.

  • Set up a PMO or Project Management Office to ensure, among others, that
    • Utilisation of facilities, budgets, technical support and other resources will be well coordinated
    • Work products can be tracked and reviewed
    • Issues regarding methodology and processes will be given appropriate attention
    • Training can be organised
    • Project management discipline be instilled in the IT department
  • Establish a steering committee to oversee the implementation of IT and business strategies
  • Fill up slots for a project manager, IT executive and a business sponsor and define the roles of each
  • Infuse project management practices to all affected units of the enterprise

Establishing PMOs, steering committees and other management structures is the easy part. Many organisations spend so much in order to create the structures related to project management, only to find out later that the effort has been all for naught. That’s why we won’t end there. Our objectives will therefore include the following:

  • To plant and cultivate an environment appreciative of project governance i.e. one that does not project it as just a bunch of bureaucratic processes and protocols.
  • To establish an organisational culture that starts at the top.
  • To make everyone involved understand that the power of project governance still lies in the hands of those who will ultimately implement it.

A project-driven enterprise is never propelled by a single project. Since multiple projects require a more complex governing structure, you’ll need to understand the intricacies of programme management.

What Kanban can do for Call Centre Response Times

When a Toyota industrial engineer named Taiichi Ohno was investigating ways to optimise production material stocks in 1953, it struck him that supermarkets already had the key. Their customers purchased food and groceries on a just-in-time basis, because they trusted continuity of supply. This enabled stores to predict demand, and ensure their suppliers kept the shelves full.

The Kanban system that Taiichi Ohno implemented included a labelling system. His Kanban tickets recorded details of the factory order, the delivery destination, and the process intended for the materials. Since then, Ohno?s system has helped in many other applications, especially where customer demand may be unpredictable.

Optimising Workflow in Call Centres
Optimising workflow in call centres involves aiming to have an agent pick up an incoming call within a few rings and deal with it effectively. Were this to be the case we would truly have a just-in-time business, in which operators arrived and left their stations according to customer demand. For this to be possible, we would need to standardise performance across the call centre team. Moving optimistically in that direction we would should do these three things:

  • Make our call centre operation nimble
  • Reduce the average time to handle calls
  • Decide an average time to answer callers

When we have done that, we are in a position to apply these norms to fluctuating call frequencies, and introduce ?kanbanned? call centre operators.

Making Call Centre Operations Nimble
The best place to start is to ask the operators and support staff what they think. Back in the 1960?s Robert Townsend of Avis Cars famously said, ?ask the people ? they know where the wheels are squeaking? and that is as true as ever.

  1. Begin by asking technical support about downtime frequencies, duration, and causes. Given the cost of labour and frustrated callers, we should have the fastest and most reliable telecoms and computer equipment we can find.
  1. Then invest in training and retraining operators, and making sure the pop-up screens are valuable, valid, and useful. They cannot do their job without this information, and it must be at least as tech-savvy as their average callers are.
  1. Finally, spruce up the call centre with more than a lick of paint to awaken a sense of enthusiasm and pride. Find time for occasional team builds and fun during breaks. Tele-operators have a difficult job. Make theirs fun!

Reducing Average Time to Handle Calls
Average length of contact is probably our most important metric. We should beware of shortening this at the cost of quality of interaction. To calculate it, use this formula:

Total Work Time + Total Hold Time + Total Post Call Time

Divided By

Total Calls Handled in that Period

Share recordings of great calls that highlight how your best operators work. Encourage role-play during training sessions so people learn by doing. Publish your average call-handling time statistics. Encourage individual operators to track how they are doing against these numbers. Make sure your customer information is up to date. While they must confirm core data, limit this so your operators can get down to their job sooner.

Decide a Target Time to Answer Calls
You should know what is possible in a matter of a few weeks. Do not attempt to go too tight on this one. It is better to build in say 10% slack that you can always trim in future. Once you have decided this, you can implement your Kanban system.

Introducing Kanban in Your Call Centre Operation
Monitor your rate of incoming calls through your contact centre, and adjust your operator-demand metric on an ongoing basis. Use this to calculate your over / under demand factor. Every operator should know the value on this Kanban ticket. It will tell them whether to speed up a little, or slow down a bit so they deliver the effort the call rate demands. It will also advise the supervisor when to call up reserves.

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How To Get Started with your IT Compliance Efforts for SOX

There’s no question about it. For many of you top executives in the corporate world, all roads leading to a brighter future have to go through SOX compliance. And because the business processes that contribute to financial reporting (the crux of the Sarbanes-Oxley Act) are now highly reliant on IT systems, it is important to focus a good part of your attention there.

It is a long and arduous path to IT compliance, so if you don’t want your company to fall by the wayside due to inefficient utilisation of resources, it is important to set out with a plan on hand. What we have here are some vital information that will guide you in putting together a sound plan for SOX compliance of your company?s IT systems.

Why focus on IT systems for SOX compliance?

We’ll get to that. But first, let’s take up the specific portions of the Sarbanes-Oxley Act that affect information technology. These portions can be found in Section 302 and Section 404 of the act.

In simplified form, Section 302 grants the SEC (Securities and Exchange Commission) authority to come up with rules requiring you, CEOs and CFOs, to certify in each annual or quarterly financial report the following:

  • that you have reviewed the report;
  • that based on your knowledge, the report does not contain anything or leave out anything that would render it misleading;
  • that based on your knowledge, all financial information in the report fairly represent the financial conditions of the company;
  • that you are responsible for establishing internal controls over financial reporting; and
  • that you have assessed the effectiveness of the internal controls.

Similarly, Section 404, stated in simplified form, allows the SEC to come up with rules requiring you, CEOs and CFOs, to add an internal control report to each annual financial report stating that you are responsible for establishing internal controls over financial reporting.

You are also required to assess the effectiveness of those controls and to have a public accounting firm to attest to your assessment based upon standards adopted by the Public Company Accounting Oversight Board (PCAOB).

While there is no mention of IT systems, IT systems now play a significant role in financial reporting. Practically all of the data you need for your financial reports are stored, retrieved and processed on IT systems, so you really have to include them in your SOX compliance initiatives and establish controls on them.

Now that that’s settled, your next question could very well be: How do you know what controls to install and whether those controls are already sufficient to achieve compliance?

Finding a suitable guide for IT compliance

The two bodies responsible for setting rules and standards dealing with SOX, SEC and PCAOB, point to a well-established control framework for guidance – COSO. This framework was drafted by the Committee of Sponsoring Organisations of the Treadway Commission (COSO) and is the most widely accepted control framework in the business world.

However, while COSO is a tested and proven framework, it is more suitable for general controls. What we recommend is a widely-used control framework that aligns well with COSO but also caters to the more technical features and issues that come with IT systems.

Taking into consideration those qualifiers, we recommend COBIT. COBIT features a well thought out collection of IT-related control objectives grouped into four domains: Plan and Organise (PO), Acquire and Implement (AI), Deliver and Support (DS), and Monitor and Evaluate (ME). The document also includes maturity models, performance goals and metrics, and activity goals.

A few examples of COBIt’s detailed control objectives are:

DS4.2 – IT Continuity Plans
DS4.9 – Offsite Backup Storage
DS5.4 – User Account Management
DS5.8 – Cryptographic Key Management
DS5.10 – Network Security
DS5.11 – Exchange of Sensitive Data

By those titles alone, you can see that the framework is specifically designed for IT. But the document is quite extensive and, chances are, you won’t need all of the items detailed there. Furthermore, don’t expect COBIT to specify a control solution controls for every control objective. For example, throughout the control objective DS4 (Ensure Continuous Service), you won’t find any mention of virtualisation, which is common in any modern business continuity solution.

Basically, COBIT will tell you what you need to attain in order to achieve effective governance, management and control, but you’ll have to pick the solution best suited to reach that level of attainment.

Articles highly relevant to the one you just read:

Month End Accounting The Way It Should Be Today
Spreadsheet Woes ? Burden in SOX Compliance and Other Regulations
Spreadsheet Woes ? Limited Features For Easy Adoption of a Control Framework
How Internal Auditors Can Win The War Against Spreadsheet Fraud

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