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


Spreadsheet Risks in Banks


Top 10 Disadvantages of Spreadsheets


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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8 Best Practices To Reduce Technical Debt

When past actions in software development return to haunt you…

Is your business being bogged down by technical debt? Let’s look at measures that you can take to reduce it and scale your operations without the weight pulling you back. 

 

Work with a flexible architecture.

Right from the word go, you want to use architecture whose design is malleable, especially with the rapid rate of software evolution witnessed today. Going with an architecture that keeps calling for too much refactoring, or whose design won’t accommodate future changes will leave you with costly technical debt. Use scalable architecture that allows you to modify or add new features in future releases. While on this, complex features required in the final product should be discussed at the planning stage, that way simplified solutions that will be easier to implement can be identified, as this will lead to less technical debt in the long run. 

 

The Deal with Refactoring 

This is basically cleaning up the code structure without changing its behaviour. With the updates, patches, and new functionalities that are added to the systems and applications, each change comes with the threat of more technical debt. Additionally, organisations are increasingly moving their IT infrastructure from on-premises facilities to colocation data centres and deploying them on the cloud. In such scenarios, some workarounds are often needed to enable the systems to function in the new environments, which they hadn’t been initially developed to accommodate. Here, you will need to take some time to refactor the existing system regularly, streamlining the code and optimizing its performance – and this will be key to pay down the tech debt. When working with a flexible architecture from the start, the amount of work that goes into this will be reduced, meaning there’ll be less tech debt involved. 

 

Run discovery tests

Discovery testing essentially takes place even before a line of code is written for the system or application. This takes place at the product definition stage, where human insight software is used to understand the needs of the customer and is particularly helpful in setting priorities for the development work that will be carried out. It gives your business the opportunity to minimize the technical debt by allowing customers to give you a roadmap of the most pertinent features desired from the product. 

 

Routine code review

Getting a fresh look at the product or application from different sets of eyes in the development team will improve the quality of the code, thus reducing technical debt. There’s a catch though – this should be planned in a convenient way that doesn’t end up becoming a burden for the developers. Here are suggestions:

● Break down pull requests

Instead of having complex pull requests where numerous changes in the code are introduced at a go, have this broken down into smaller manageable pull requests, each with a brief title and description about it. This will be easier for the code reviewer to analyse. 

● Define preferred coding practices

Documenting the preferred coding style will result in cleaner code, meaning the developers will focus their effort on reviewing the code itself, not losing time on code format debates.

 

Test automation

Relying only on scheduled manual testing opens you up to the risk of technical debt accruing rapidly, and not having sufficient resources to deal with the accumulated problems when they are identified. Automated testing on the other hand enables issues to be uncovered quicker, and with more precision. For instance, you can have automated unit tests that look at the functioning of the individual components of a system, or regression testing where the focus is on whether the code changes that have been implemented have affected related components of the system. However, establishing and maintaining automated testing will require quite some effort – making it more feasible for the long-term projects.

 

Keep a repository that tracks changes made

Do you have a record of changes made in the software? Keeping one in a repository that is accessible by the development team will make it easy to pin-point problems at their source. For instance, when software is being migrated to a new environment, or legacy software is in the process of being modernised, you will want to have an accurate record of changes that are being introduced, that way if there is an undesired impact on the system this it will be easier to zero-down on the cause.

 

Bring non-technical stakeholders on board

Does this conversation sound familiar?

Development Team: “We need to refactor the messy code quickly”

Product Team: “We have no idea what you are saying”

On one hand, you have the management or product team defining the product requirements, creating a project roadmap, and setting its milestones. On the other hand, there’s the software development/engineering that’s primarily focused on the product functionality, technical operations and clearing the backlog in code fixes. Poor communication between the two teams is actually a leading cause of technical debt.

For you to take concrete steps in managing your technical debt, the decision-makers in the organisation should understand its significance, and the necessity of reducing it. Explain to them how the debt occurred and why steps need to be taken to pay it down – but you can’t just bombard them with tech phrases and expect them to follow your thought process. 

So how do you go about it? Reframe the issues involved with the technical debt and explain the business value or impact of the code changes. Basically, the development team should approach it from a business point of view, and educate the management or production team about the cost of the technical debt. This can include aspects such as expenses in changing the code, salaries for the software engineers especially when the development team will need to be increased due to the workload piling up, as well as the revenue that is lost when the technical debt is allowed to spiral. 

The goal here is to show the management or production team how issues like failing to properly define the product requirements will slow down future software development, or how rushing the code will affect the next releases. That way, there will be better collaboration between the teams involved in the project. 

 

Allocate time and resources specifically for reducing technical debt

With management understanding that working with low-quality code is just like incurring financial debt and it will slow down product development, insist on setting time to deal with the debt. 

For instance, when it comes to the timing of application releases, meetings can be conducted to review short- and longer-term priorities. These meetings – where the development team and product team or management are brought together, the developers point out the software issues that should be resolved as a priority as they may create more technical debt. Management then ensures that budgets and plans are put in place to explicitly deal with those ongoing maintenance costs.

 

Retire old platforms

While most of the resources are going into developing new applications and improving the systems being used, the organisation should also focus on retiring the old applications, libraries, platforms, and the code modules. It’s recommended that you factor this into the application release plans, complete with the dates, processes and costs for the systems involved. 

 

Total overhaul

When the cost and effort of dealing with the technical debt far outweighs the benefits, then you may have to replace the entire system. At this tipping point, you’re not getting value from the technical debt, and it has become a painful issue that’s causing your organisation lots of difficulties. For instance, you may be dealing with legacy software where fixing it to support future developments has simply become too complicated. The patches available may only resolve specific issues with the system, and still leave you with lots of technical debt. Here, the best way out is to replace the system in its entirety. 

 

Final thoughts

Every software company has some level of tech debt. Just like financial debt, it is useful when properly managed, and a problem when ignored or allowed to spiral out of control. It’s a tradeoff between design/development actions and business goals. By taking measures to pay down your organization’s debt and address its interest as it accrues, you will avoid situations where short term solutions undermine your long-term goals. This is also key to enable your business to transition to using complex IT solutions easier, and even make the migration between data centres much smoother. These 8 measures will enable you to manage your technical debt better to prevent it from being the bottleneck that stifles your growth.

Symbion Pharmacy Services? Definition of Responsibility

A ?symbion? is an organism in a symbiotic (i.e. mutually beneficial) relationship with another one. In the case of Australia?s giant Symbion Pharmacy Services, this means supplying and delivering over-counter Chemmart medicines to more than 3,000 hospital and retail pharmacies, while remaining mindful of its carbon footprint.

In 1999, the company with the tagline ?life matters? and a desire to be seen as ?a good corporate citizen? decided it was time to measure exactly what it was pumping out from 12 facilities and over 200 vehicles. This was a voluntary decision as even now there is still no carbon emissions law in Australia (although no doubt being a ?first mover? will put the company in a competitive position when this inevitably comes).

Symbion decided to install emission detection devices and connect these to a central monitoring system with the intention of managing what these measured. There were two stages to this process. First, Symbion determined its reporting requirements based on one of its larger warehouses. Following that, it established a carbon footprint for each of its wholly owned and managed facilities. This put it in a position to:

  • Analyse total emissions down to a level of detail where it understood the contribution of each source
  • Use big data management tools to identify carbon hotspots for priority remedial action
  • Inform the affected workforce, explain the monitoring system and keep them in the loop
  • Separately manage energy abatement programs such as lighting and delivery routes

The program also had productivity spin-offs in that it focused management attention on the processes behind the emissions that were ripe for material and system improvements. It also provided marketing leverage. Symbion?s customers are in the wellness business, ahead of the curve when it comes to how emissions contribute to chronic illness, and aware of the cost of this in terms of human capital.

EcoVaro could help you manage your throughputs by analysing your data on our cloud-based system. This includes trending your metrics, comparing them to your industry seasonal average, and providing you with a business-like view of how well you are doing.

Our service reduces your reliance on (and the cost of) third party audits, and simplifies the reporting process to your controlling authority. It simply makes more sense to contract your software out this way, and only pay for it when you need it.

What ISO 14001 Status did for Cummins Inc.

Cummins manufactures engines and power generation products, and has been a household name almost since inception in 1919. It sells its products in over 300 countries, through approximately 6,000 dealerships employing 40,000 people. Because its product line runs off fossil fuel it is under steady pressure to display a cleaner carbon footprint.

Cummins decided to go for the big one by qualifying for ISO 14001 certification. This is a subset of a family of standards relating to managing environmental impact while complying with all applicable legislation. In this sense, it is similar to the ISO 9000 quality management system, because it focuses on how products are produced (as opposed to how those products perform). Compliance with ISO 14001 was a doubly important goal, because it is part of the European Union?s Eco Management and Audit Scheme and fast becoming mandatory on suppliers to governments.

The qualification process follows the well-established principle of plan, do, check, act. It begins with gap analysis to detect materials and processes that affect the environment. This is followed by implementation of necessary changes affecting operations, documentation, emergency strategies and employee education. The third step involves measuring and monitoring performance. Finally, the project moves into a phase of ongoing maintenance, and continuous improvement as circumstances change.

In Cummins case, the project was almost worldwide and called for environmental, health and safety reporting throughout the organisation. The information was shared via a globally accessible document repository, and then processed centrally at the head office in Columbia, Indiana USA.

Measuring environmental performance almost inevitably has other benefits that make it doubly worthwhile. Speaking at the 2014 National Safety Council Congress after receiving the top award for excellence, Cummins chairman and ceo Tom Linebarger commented on a journey that was ?nothing short of amazing? yet wasn’t even a ?pathway to the finish line?.

?All of us feel like we have way more to do to make sure that our environment is as safe as it could be,? he added, ?so that our sustainability footprint is as good as it can be and that we continue to set more aggressive goals every year. That’s just how we think about it.? Linebarger concluded.

If you are taking your company on a journey to new heights of environmental excellence, then you should consider choosing ecoVaro as your travelling companion. We are environmental management specialists and have proprietary software geared to process your data. We also have a wealth of experience, and a treasure chest of roadmaps to help you achieve your goal.

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