2015 ESOS Guidelines Chapter 6 – Role of Lead Assessor
The primary role of the lead assessor is to make sure the enterprise?s assessment meets ESOS requirements. Their contribution is mandatory, with the only exception being where 100% of energy consumption received attention in an ISO 50001 that forms the basis of the ESOS report.
How to Find a Lead Assessor
An enterprise subject to ESOS must negotiate with a lead assessor with the necessary specialisms from one of the panels approved by the UK government. This can be a person within the organisation or an third party. If independent, then only one director of the enterprise need countersign the assessment report. If an employee, then two signatures are necessary. Before reaching a decision, consider
Whether the person has auditing experience in the sector
Whether they are familiar with the technology and the processes
Whether they have experience of auditing against a standard
The choice rests on the enterprise itself. The lead assessor performs the appointed role.
The Lead Assessor?s Role
The Lead Assessor?s main job is reviewing an ESOS assessment prepared by others against the standard, and deciding whether it meets the requirements. They may also contribute towards it. Typically their role includes:
Checking the calculation for total energy consumption across the entire enterprise
Reviewing the process whereby the 90% areas of significant consumption were identified
Confirming that certifications are in place for all alternate routes to compliance chosen
Checking that the audit reports meet the minimum criteria laid down by the ESOS system
Note: A lead assessor may partly prepare the assessment themselves, or simply verify that others did it correctly.
In the former instance a lead assessor might
Determine energy use profiles
Identify savings opportunities
Calculate savings measures
Present audit findings
Determine future methodology
Define sampling methods
Develop audit timetables
Establish site visit programs
Assemble ESOS information pack
Core Enterprise Responsibilities
The enterprise cannot absolve itself from responsibility for good governance. Accordingly, it remains liable for
Ensuring compliance with ESOS requirements
Selecting and appointing the lead assessor
Drawing attention to previous audit work
Agreeing with what the lead assessor does
Requesting directors to sign the assessment
The Environment Agency does not provide assessment templates as it believes this reduces the administrative burden on the enterprises it serves.
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.
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DevOps creates an agile relationship between system development and operating departments, so the two collaborate in providing results that are technically effective, and work well for customers and users. This is an improvement over the traditional model where development delivers a complete design ? and then spends weeks and even months afterwards, fixing client side problems that should never have occurred.
Writing for Tech Radar Nigel Wilson explains why it is important to roll out innovation quickly to leverage advantage. This implies the need for a flexible organisation capable of thinking on its feet and forming matrix-based project teams to ensure that development is reliable and cost effective.
Skirmishes in Boardrooms
This cooperative approach runs counter to traditional silo thinking, where Operations does not understand Development, while Development treats the former as problem children. This is a natural outcome of team-centred psychology. It is also the reason why different functions pull up drawbridges at the entrance to their silos. This situation needs managing before it corrodes organization effectiveness. DevOps aims to cut through this spider web of conflict and produce faster results.
The Seeds of Collaboration
Social and personal relationships work best when the strengths of each party compensate the deficiencies of the other. In the case of development and operations, development lacks full understanding of the daily practicalities operating staff face. Conversely, operations lacks ? and should lack knowledge of the nuances of digital automation, for the very reason it is not their business.
DevOps straddles the gap between these silos by building bridges towards a co-operative way of thinking, in which matrix-teams work together to define a problem, translate it into needs and spec the system to resolve these. It is more a culture than a method. Behavioural change naturally leads to contiguous delivery and ongoing deployment. Needless to say only the very best need apply for the roles of client representative, functional tester and developer lead.
Is DevOps Worth the Pain of Change?
Breaking down silos encroaches on individual managers? turf. We should only automate to improve quality and save money. These savings often distil into organisational change. The matrix team may find itself in the middle of a catfight. Despite the pain associated with change resistance, DevOps more than pays its way in terms of benefits gained. We close by considering what these advantages are.
An Agile Matrix Structure ? Technical innovation is happening at a blistering rate. The IT industry can no longer afford to churn out inferior designs that take longer to fix than to create. We cannot afford to allow office politics to stand in the way of progress. Silos and team builds are custodians of routine and that does not sit well with development.
An Integrated Organization ? DevOps not only delivers operational systems faster through contiguous testing. It also creates an environment whereby cross-border teams work together towards achieving a shared objective. When development understands the challenges that operations faces ? and operations understands the technical limiters – a new perspective emerges of ?we are in this together?.
The Final Word ? With understanding of human dynamics pocketed, a DevOps project may be easier to commission than you first think. The traditional way of doing development – and the waterfall delivery at the end is akin to a two-phase production line, in which liaison is the weakest link and loss of quality inevitable.
DevOps avoids this risk by having parties work side-by-side. We need them both to produce the desired results. This is least until robotics takes over and there is no longer a human element in play.
A mobile workforce management software is key to managing an efficient field workforce.? Managing a staff of people can be tricky in any industry. Try keeping track of employees on shifting jobsites, many whom are paid hourly or temporary workers. The added pressure of ensuring the right workers get to the right sites at the right times, but they also need to track hours, parts used, vehicles and equipment assets.
In a previous post, we defined what is an operational review and why they play a key process in the continual evolution of successful businesses.?
Operational reviews allow the organization members to evaluate their performance, according to the procedures, resources properly, timescales and budgets.
In this post, we’ll take a closer look at how to implement an operational review and the steps typically undertaken to help you and your organisation to implement an operational review.
What the steps in a Operational Review Process
There are typically six steps in an operational review that range from preparatory work conducting interviews and collecting documents to the presentation of the final written report.
An audit should be customized to meet a organisatons specific needs, so standard steps can and should only serve as a guideline.? Management and internal and external auditors should adjust the process to address the company’s particular goals and objectives.
Initial Management Meeting
Understanding the problem is the first crucial step of an operational review. This is one of major areas of discussions when the audit team meets with the management, and department heads will be asked to identify any specific areas of concern. Once the problem is identified, it would be easier to come up with workable solutions.
Conduct Interviews
The next step in the evaluation is carried out with experienced teams doing interviews and keeping close observation. Each team essentially watches how employees carry out their responsibilities. This is considered a key part of the process.
When doing the interview, it is also vital that the observing team gains the employees? trust and confidence. Likewise, the staff must be assured that whatever transpires between the team and the employee will be kept confidential. Management must therefore guarantee anonymity to anyone who offers critical information, lest employees withhold vital information and render the data gathered inaccurate.
Systems Review
Employees and management practices will be reviewed by the assessing team according to the standard policies and guidelines of the company. The effectiveness of the controls in place as well as their appropriateness to the current operating conditions will also be evaluated.
Reporting
A documentation of the data gathered and the assessment of the evaluating team, will be submitted to the management after the review process. Flow charts and written narratives of departmental activities are usually part of this report. This is also where observations and recommendations of the team will be presented to the department heads concerned.
Review Results
While the operational review is being conducted, it is important to take into account the vital factors that affect the company: the people, processes, procedures, and strategies. These four factors can determine the company?s progress in the future.
Key Areas of focus in operation reviews
At a minimum an operational review should include the following key ares of assessment
Management Control
Responsibilities, authority, and the scope in which an employee has the freedom to act must be clearly defined and documented. A complete and specific job description for instance, would give the employee a clear perspective on how he acts and functions within the company.
Boundaries should be set not only to benefit the employer but more so the employee as well.
Moral and Ethical Guidelines
Moral and ethical guidelines are just as important to ensure for a smoother employer?employee relationship. Otherwise, personal issues such as work ethics, work attitude and personal values may post problems in the long run if such guidelines are not drawn properly before relationships are established.
Processes and procedures
Evaluating processes is only beneficial if the company itself updates its processes and procedural manuals regularly, or at least when needed. Such protocols may need revision and some steps may be obsolete already. Improving a company?s processes and procedures doesn’t always entail cost. In fact, improvised procedures may even be cost-effective and could make the processes more manageable.
Communication and reporting standards
Gaps in communication could result in serious lapses in internal controls, putting the company and/or its assets at risk. This is where the importance of timely and clear communication comes in. Likewise, reports must be useful, and the flow of information and how it is processed must keep pace with the company?s growth.
Information technology (IT) and security controls can also be included under the communication clause. Proper IT security policies must be in place, state-of-the-art protection techniques employed, and everything be documented, periodically updated, and continually monitored.
Strategic planning and tactics
No company can ever be complete without its strategies. It would unwise for any organization to proceed without first knowing where it stands and what direction it wants to take. Strategic planning draws such a map. It must be aligned to the mission and vision of the company, and should also coincide with the organizational goals set. Strategic planning deals with these three key questions:
What do we do now
Whom do we do it for?
How can we overcome competition
Without clear strategic direction, expectations would likely differ between ownership and management.
Contingency planning, testing and recovery
Contingency plans must be up-to-date, and are essential to the organization. If one course of action fails, the company should have plan B, C and so on. In addition, an organization should be prepared to respond to interference’s.
This includes establishing a formal process to review transactions processing during both disruption and recovery.
Presentation of Report
Based on your objectives and our findings, we will develop detailed recommendations to improve your company?s performance and productivity. Our written report will include a list of both short-term and long-term projected improvements and courses of action, to be mutually agreed upon by both parties.
To ensure the achievement of the improvements we outlined, our team will also assist in the implementation of these modifications.
The plan has three levels of recommendations: one for executives, another for management, and a third one for staff.
The executive summary concentrates on your company?s strengths, weaknesses, opportunities and threats to its entirety. It includes recommendations for any needed changes in policy or governance.
The management plan is based on employee feedback and includes areas of immediate improvement as well as identification of potential problem areas. Concerns from the bottom level management can now be forwarded to the top level management in formal writing. Better working relationships may evolve from this, thereby setting the work environment for a higher productivity ratio.
Lastly, the staff report deals with topics like charting the hierarchy of the organization, and discussing in detail specific control objectives that are critical to the company?s mission. Part of our goal is to encourage personnel to pay close attentions to such changes, if any, as these efforts are essential if they want to bring about both organizational and personal success.
If you would like to further discuss how our operational review services can benefit your company, please feel free to contact us at your convenience to schedule an initial consultation. We?ll be more than happy to assist you.
