Why Spreadsheets can send the Pillars of Solvency II Crashing Down


Solvency II is now fast approaching and while it may provide added protection to policy holders, its impact on the insurance industry is not all a bed of roses. Expect insurance companies to restructure, increase manpower, and raise spending on actuarial operations and risk management initiatives. Those that cannot, will have to go. But what have spreadsheets got to do with all these?

Well, spreadsheets aren’t really the main casts in this blockbuster of a regulatory exercise but they certainly have a significant supporting role to play. Pillar I of Solvency II, which calls for improved supervision on internal control, risk management, and corporate governance, and Pillar II, which tackles supervisory reporting and public disclosure of financial and other relevant information, both affect systems that have high-reliance on spreadsheets.

A little background about spreadsheets might help.

Who needs an IT solution when you can have spreadsheets?

Everyone in any organisation just love spreadsheets; from the office clerk to the CEO. Because they’re so easy to use (not to mention they’re a staple in office computers), people employ them for processing numbers and as an all-around tool for planning, forecasting, reporting, complex modelling, market data analysis, and so on. They make such tasks faster and easier. Really?

You probably haven’t heard of spreadsheet hell

Unfortunately, spreadsheets do have certain shortcomings. Due to their inherent structure and lack of controls, it is so easy to commit simple errors like an accidental copy paste, an omission of a negative sign, an incorrect data input, or an unintentional deletion. Such shortcomings may seem harmless until your shareholders discover a multi-million discrepancy in your financial report.

And because spreadsheet errors can go undetected for a long time, they are constant targets of fraudsters. In other words, spreadsheets are high risk applications.

Solvency II Impact on Spreadsheet-based Financial and IT Systems

Regulations like Solvency II, are aimed at reducing risks to manageable levels. Basically, Solvency II is a risk-based system wherein a company?s capital requirements will depend on its measured riskiness. If companies want to avoid facing onerous capital requirements, they have to comply.

The three pillars of Solvency II have to be in place. Now, since spreadsheets (also known as User Developed Applications or UDAs) are high-risk applications with weak control features and prone to produce inaccurate reports, companies will have a lot of work to do to establish Pillars II and III.

There are at least 8 articles that impact spreadsheets in the directive. Article 82, for example, which requires firms to ensure a high level of data quality and accuracy, strikes at the very core of spreadsheets? weakness.

A whitepaper by Raymond Panko entitled ?Spreadsheets and Sarbanes-Oxley: Regulations, Risks, and Control Frameworks? mentioned that 94% of audited real world operational spreadsheets that were included in his study were found to have errors and that an average of 5.2% of all cells in the audited spreadsheets had errors.

Furthermore, many articles in the directive call for the enforcement of better documentation. This is one thing that’s very tedious and almost unrealistic to do with spreadsheets because just about anyone uses them. Besides, with different ‘versions? of the same data existing in different workstations throughout the organisation, it would be extremely difficult to keep track of them all.

Because of spreadsheets you now need an IT solution

It is clear that, with the growing number of regulations and the mounting complexity of tasks needed for compliance, spreadsheets no longer belong in this era. What you need is a server-based solution that allows for seamless collaboration, data reliability, data consistency, increased security, automatic consolidation, and all the other features that make regulation compliance more doable.

One important ingredient for achieving Solvency II compliance is sound data risk management. Sad to say, the ubiquitous spreadsheet will only expose your data to more risks.

More Spreadsheet Blogs


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Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry


How Internal Auditors can win the War against Spreadsheet Fraud


Spreadsheet Reporting – No Room in your company in an age of Business Intelligence


Still looking for a Way to Consolidate Excel Spreadsheets?


Disadvantages of Spreadsheets


Spreadsheet woes – ill equipped for an Agile Business Environment


Spreadsheet Fraud


Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


Server Application Solutions – Don’t let Spreadsheets hold your Business back


Why Spreadsheets can send the pillars of Solvency II crashing down

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IT Systems Implementation

Are you ready to find out how your newly accepted IT system fares in the real world? Although a rigorous Acceptance testing process can spot a wide spectrum of flaws in a newly constructed IT system, there is no way it can identify all possible defects. The moment the IT system is delivered into the hands of actual end users and other stakeholders, it is effectively stepping out of a controlled and secure environment.

Thus, it is during this phase wherein issues having direct impact on the business can arise.

It is our duty to ensure that the Systems Implementation phase is carried out as thoroughly, professionally, and efficiently as possible.

Thoroughly, because we need to include all relevant data and other deliverables, eliminate hard-to-detect miscalculated results, and substantially reduce the probability of business and mission critical issues popping up in the future;

Professionally, because it is the best way to address the sensitive process of turning over a new system to users who have gotten used to the old one;

And efficiently, because we want to minimise the duration over which all stakeholders have to adapt to the new system and allow them to move on to the process of growing the business.

Preparation

Louis Pasteur once said, “Luck favours the mind that is prepared.”

While we certainly won’t leave anything to chance, we do put substantial weight on the Preparation stage of Systems Implementation. We’re so confident with the strategies we employ in Preparation, that we can assure you of an utterly seamless Deployment and Transition phase.

By this we mean that issues that may arise during Deployment and Transition will be handled smoothly and efficiently because your people will know exactly what to do.

Here’s how we will prepare your organisation for Deployment:

  • Identify all key players for the Systems Implementation phase and orient them on their specific roles. We’ll make sure they know what possible hitches may come their way and how to deal with them.
  • Identify all end users and their corresponding functions, then assign appropriate access rights.
  • Draw multi-layered contingency plans to capture and address each possible concern that may crop up during Deployment.
  • Prepare a systematic step-by-step procedure and checklist for the entire Deployment stage. Both of them should have been copied from a similar procedure and checklist used in the Acceptance testing phase.
  • Make all stakeholders understand the conditions required before Deployment can commence.
  • Set the appropriate environment so that all stakeholders know what to expect and when to expect them the moment Deployment commences.
  • Prepare Technical Services and Technical Support personnel for the gruelling mission ahead.
  • Make sure all communication processes are well coordinated so that everyone affected will know who to contact and how to get in touch with them when a problem arises.
  • Plan and schedule training sessions so that they can be conducted “just in time”. Training sessions conducted way ahead of Deployment are often useless because the trainees tend to forget about what they learned when the time comes to apply them. Similarly, training sessions conducted way after Deployment also become useless because trainees are seldom able to internalise instructions delivered during crash courses.

Deployment

There are two sets of issues to keep an eye on during Deployment:

  1. Issues directly related to the technology itself, e.g. application functionality and data integrity, and
  2. Issues emanating from the end users, i.e., their unwillingness to use the new system. One reason may be because they find the interface and procedures too confusing. Another would be due to other inconveniences that come with adapting to a new set of procedures.

Despite all the meticulous scrutiny employed during Acceptance testing, there are just some problems that are made obvious only during Deployment. Issues belonging to the first set are dealt with easily because of the plans and procedures we put in place during the Preparation stage. As an added measure, our team will be on hand to make sure contingency plans are executed accordingly.

While the second set of issues is often neglected by many IT consultancy companies, we choose to meet it head on.

We fully understand that end users are most sensitive to the major changes that accompany a new system. It is precisely for this reason why our training activities during Deployment are designed not only to educate them but also to make them fully appreciate the necessity of both the new system and the familiarisation phase they will need to go through.

The faster we can bring your end users to accept the new system, the faster they can refocus on your company’s business objectives.

Here’s what we’ll do to guarantee the smoothest Deployment process you’ve ever experienced.

  • Employ the procedure and checklist formulated during the Preparation stage.
  • Ensure all end users are well acquainted with any additional tasks they would need to perform (e.g. filling up manual logs).
  • Assess which legacy systems can still be used alongside the new technology and which ones have to be retired.
  • Supervise the installation and optimal configuration of all supporting hardware and software to make sure the likelihood of errors originating from them are brought to near-zero levels.
  • Supervise the installation and optimal configuration of the products themselves.
  • Carry out data migration tasks if necessary.
  • Organise and oversee parallel runs to check for data and report inconsistencies.
  • Conduct training sessions in a professional and well-timed manner to eliminate end-users’ feelings of agitation and to take advantage of memory absorption and retention duration as with regards to their assigned duties and responsibilities.

Transition

Do you often feel uneasy whenever the reins to a newly purchased IT system are handed over to you? Perhaps there are some issues that you feel haven’t been fully settled but, at the same time, find it too late to back out, having already invested so much time and resources.

Alright, so maybe the thought of “backing up” never crossed your mind. However, the concern of being “not yet ready” is raised by many organisations towards the tail end of most Deployment stages. This usually drags the Deployment stage into a never-ending process.

Our team of highly experienced specialists will make sure you reach this point with utmost confidence to proceed on your own.

To wrap up our comprehensive IT Systems Implementation offering, we’ll take charge of the following:

  • Verify that all deliverables, including training materials and other technical documentation, are accomplished and expected outcomes are realised.
  • Make sure all technical documentation are placed in a secure and accessible location.
  • Institute best practices to ensure the IT system becomes fully utilised and to reduce its exposure to avoidable risks.
  • Establish open communication lines with the Technical Support team to enable quick resolution of issues.
  • Ensure complete knowledge transfer has been fully achieved so that your people will spend less time calling Technical Support and more on operations contributory to business growth.
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.

Saving Energy Step 5 – Bringing it together

We hope you have been enjoying our series of short posts regarding saving energy, so what we use we can sustain. We have tried to make a dry subject interesting. After you read this post please comment, and tell us how it went. We are in the environment together. As the man who wrote ?No Man is an Island? said, ?if a clod be washed away somewhere by the sea, Europe is the less? and Europe was his entire world.

The 4 Steps we wrote about previously have a multiplier effect when we harness them together

  1. Having a management system diffuses office politics and pins accountability in a way that not even a worm could wriggle
  2. This defines the boundaries for senior managers and empowers them to implement practical improvements with confidence
  3. The results feed back into lower energy bills: this convinces the organisation that more is possible
  4. This dream filters through all levels of the organisation, as a natural team forms to make work and home a better place.

None of this would be possible without measuring energy consumption throughout the process, converting this into meaningful analytics, and playing ?what-if? scenarios against each other to determine where to start.

The 5th Step to Energy Saving that brings the other four together can double the individual benefits as innovative power flows between them. The monetary savings are impressive and provide capital to go even further. Why not allow us to help you manage what we measure together.

ecoVaro turns your numbers into meaningful analytics, makes suggestions, and stays with you so we can quantify your savings as you make them. We should talk about this soon.

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