How COBIT helps you achieve SOX Compliance

First released way back in 1996, COBIT has already been around for quite a while. One reason why it never took off was because companies were never compelled to use it ? until now. Today, many CEOs and CIOs are finding it to be a vital tool for achieving SOX compliance in IT.

Thanks to SOX, COBIT (Control Objectives for Information and related Technology) is now one of the most widely accepted source of guidance among companies who have IT integrated with their accounting/financial systems. It has also gained general acceptability with third parties and regulators. But how did this happen?

Role of control frameworks in SOX compliance

You see, the Sarbanes-Oxley Act, despite having clearly manifested the urgency of establishing effective internal controls, does not provide a road map for you to follow nor does it specify a yardstick to help you determine whether an acceptable mileage in the right direction has already been achieved.

In other words, if you were a CIO and you wanted to find guidance on what steps you had to take to achieve compliance, you wouldn’t be able to find the answers in the legislation itself.

That can be a big problem. Two of your main SOX compliance obligations as a CEO or CIO is to assume responsibility in establishing internal controls over financial reporting and to certify their effectiveness. After that, the external auditors are supposed to attest to your assertions. Obviously, there has to be a well-defined basis before you can make such assertions and auditors can attest to anything.

In the language of auditors, this ?well-defined basis? is known as a control framework. Simply put, once you certify the presence of adequate internal controls in your organisation, the external auditor will ask, ?What control framework did you use??

Knowing what control framework you employed will help external auditors determine how to proceed with their evaluations and tests. For your part, a control framework can serve as a guide to help you work towards specific objectives for achieving compliance. Both of you can use it as a common reference point before drawing any conclusions regarding your controls.

But there are many control frameworks out there. What should you use?

How SOX, COSO, and COBIT fit together

Fortunately, despite SOX?s silence regarding control frameworks, you aren’t left entirely to your own devices. You could actually take a hint from the SEC and PCAOB, two of the lead organisations responsible for implementing SOX. SEC and PCAOB point to the adoption of any widely accepted control framework.

In this regard, they both highly endorse COSO, a well-established internal control framework formulated by the Committee of Sponsoring Organisations of the Treadway Commission (COSO). Now, I must tell you, if you’re looking specifically for instructions pertaining to IT controls, you won’t find those in COSO either.

Although COSO is the most established control framework for enterprise governance and risk management you’ll ever find (and in fact, it’s what we recommend for your general accounting processes), it lacks many IT-related details. What is therefore needed for your IT processes is a framework that, in addition to being highly aligned with COSO, also provides more detailed considerations for IT.

This is where COBIT fits the bill.

How COBIT can contribute to your regulatory compliance endeavors

COBIT builds upon and adheres with COSO while providing a finer grain of detail focused on IT. You can even find a mapping between COBIT IT processes and COSO components within the COBIT document itself.

Designed with regulatory compliance in mind, COBIT lays down a clear path for developing policies and good practice for IT control, thus enabling you to bridge the gap between control requirements, technical issues, and business risks.

Some of the components you’ll find in COBIT include:

IT control objectives

These are statements defining specific desired results that, as a whole, characterise a well-managed IT process. They come in two forms for each COBIT-defined IT process: a high-level control objective and a number of detailed control objectives. These objectives will enable you to have a sense of direction by telling you exactly what you need to aim for.

Maturity models

These are used as benchmarks that give you a relative measurement stating where your level of management or control over an IT process or high-level control objective stands. It serves as a basis for setting as-is and to-be positions and enables support for gap analysis, which determines what needs to be done to achieve a chosen level. Basically, if a control objective points you to a direction, then its corresponding maturity model tells you how far in that direction you’ve gone.

RACI charts

These charts tell you who (e.g. CEO, CFO, Head of Operations, Head of IT Administration) should be Responsible, Accountable, Consulted, and Informed for each activity.

Goals and Metrics

These are sets of goals along with the corresponding metrics that allow you to measure against those goals. Goals and metrics are defined in three levels: IT goals and metrics, which define what business expects from IT; process goals and metrics, which define what the IT process should deliver to support It’s objectives; and activity goals and metrics, which measure how well the process is performing.

In addition to those, you’ll also find mappings of each process to the information criteria involved, IT resources that need to be leveraged, and the governance focus areas that are affected.

Everything is presented in a logical and manageable structure, so that you can easily draw connections between IT processes and business goals, which will in turn help you decide what appropriate governance and control is needed. Ultimately, COBIT can equip you with the right tools to maintain a cost-benefit balance as you work towards achieving SOX compliance.

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Which Services to Share?

It often makes sense to pool resources. Farmers have been doing so for decades by collectively owning expensive combine harvesters. France, Germany, the United Kingdom and Spain have successfully pooled their manufacturing power to take on Boeing with their Airbus. But does this mean that shared services are right in every situation?

The Main Reasons for Sharing

The primary argument is economies of scale. If the Airbus partners each made 25% of the engines their production lines would be shorter and they would collectively need more technicians and tools. The second line of reasoning is that shared processes are more efficient, because there are greater opportunities for standardisation.

Is This the Same as Outsourcing?

Definitely not! If France, Germany, the United Kingdom and Spain has decided to form a collective airline and asked Boeing to build their fleet of aircraft, then they would have outsourced airplane manufacture and lost a strategic industry. This is where the bigger picture comes into play.

The Downside of Sharing

Centralising activities can cause havoc with workflow, and implode decentralised structures that have evolved over time. The Airbus technology called for creative ways to move aircraft fuselages around. In the case of farmers, they had to learn to be patient and accept that they would not always harvest at the optimum time.

Things Best Not Shared

Core business is what brings in the money, and this should be tailor-made to its market. It is also what keeps the company afloat and therefore best kept on board. The core business of the French, German, United Kingdom and Spanish civilian aircraft industry is transporting passengers. This is why they are able to share an aircraft supply chain that spun off into a commercial success story.

Things Best Shared

It follows that activities that are neither core nor place bound – and can therefore happen anywhere ? are the best targets for sharing. Anything processed on a computer can be processed on a remote computer. This is why automated accounting, stock control and human resources are the perfect services to share.

So Case Closed Then?

No, not quite. ?Technology has yet to overtake our humanity, our desire to feel part of the process and our need to feel valued. When an employee, supplier or customer has a problem with our administration it’s just not good enough to abdicate and say ?Oh, you have to speak to Dublin, they do it there?.

Call centres are a good example of abdication from stakeholder care. To an extent, these have ?confiscated? the right of customers to speak to speak directly to their providers. This has cost businesses more customers that they may wish to measure. Sharing services is not about relinquishing the duty to remain in touch. It is simply a more efficient way of managing routine matters.

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.

What Is Technical Debt? A Complete Guide

You buy the latest iPhone on credit. Turn to fast car loan services to get yourself those wheels you’ve been eyeing for a while. Take out a mortgage to realise your dream of being a homeowner. Regardless of the motive, the common denominator is going into financial debt to achieve something today, and pay it off in future, with interest. The final cost will be higher than the loan value that you took out in the first place. However, debt is not limited to the financial world.

Technical Debt Definition

Technical debt – which is also referred to as code debt, design debt or tech debt – is the result of the development team taking shortcuts in the code to release a product today, which will need to be fixed later on. The quality of the code takes a backseat to issues like market forces, such as when there’s pressure to get a product out there to beat a deadline, front-run the competition, or even calm jittery consumers. Creating perfect code would take time, so the team opts for a compromised version, which they will come back later to resolve. It’s basically using a speedy temporary fix instead of waiting for a more comprehensive solution whose development would be slower.

How rampant is it? 25% of the development time in large software organisations is actually spent dealing with tech debt, according to a multiple case study of 15 organizations. “Large” here means organizations with over 250 employees. It is estimated that global technical debt will cost companies $4 trillion by 2024.

Is there interest on technical debt?

When you take out a mortgage or service a car loan, the longer that it takes to clear it the higher the interest will be. A similar case applies to technical debt. In the rush to release the software, it comes with problems like bugs in the code, incompatibility with some applications that would need it, absent documentation, and other issues that pop up over time. This will affect the usability of the product, slow down operations – and even grind systems to a halt, costing your business. Here’s the catch: just like the financial loan, the longer that one takes before resolving the issues with rushed software, the greater the problems will pile up, and more it will take to rectify and implement changes. This additional rework that will be required in future is the interest on the technical debt.

Reasons For Getting Into Technical Debt

In the financial world, there are good and bad reasons for getting into debt. Taking a loan to boost your business cashflow or buy that piece of land where you will build your home – these are understandable. Buying an expensive umbrella on credit because ‘it will go with your outfit‘ won’t win you an award for prudent financial management. This also applies to technical debt.

There are situations where product delivery takes precedence over having completely clean code, such as for start-ups that need their operations to keep running for the brand to remain relevant, a fintech app that consumers rely on daily, or situations where user feedback is needed for modifications to be made to the software early. On the other hand, incurring technical debt because the design team chooses to focus on other products that are more interesting, thus neglecting the software and only releasing a “just-usable” version will be a bad reason.

Some of the common reasons for technical debt include:

  • Inadequate project definition at the start – Where failing to accurately define product requirements up-front leads to software development that will need to be reworked later
  • Business pressure – Here the business is under pressure to release a product, such as an app or upgrade quickly before the required changes to the code are completed.
  • Lacking a test suite – Without the environment to exhaustively check for bugs and apply fixes before the public release of a product, more resources will be required later to resolve them as they arise.
  • Poor collaboration – From inadequate communication amongst the different product development teams and across the business hierarchy, to junior developers not being mentored properly, these will contribute to technical debt with the products that are released.
  • Lack of documentation – Have you launched code without its supporting documentation? This is a debt that will need to be fulfilled.
  • Parallel development – This is seen when working on different sections of a product in isolation which will, later on, need to be merged into a single source. The greater the extent of modification on an individual branch – especially when it affects its compatibility with the rest of the code, the higher the technical debt.
  • Skipping industrial standards – If you fail to adhere to industry-standard features and technologies when developing the product, there will be technical debt because you will eventually need to rework the product to align with them for it to continue being relevant.
  • Last-minute product changes – Incorporating changes that hadn’t been planned for just before its release will affect the future development of the product due to the checks, documentation and modifications that will be required later on

Types of Technical Debt

There are various types of technical debt, and this will largely depend on how you look at it.

  • Intentional technical debt – which is the debt that is consciously taken on as a strategy in the business operations.
  • Unintentional technical debt – where the debt is non-strategic, usually the consequences of a poor job being done.

This is further expounded in the Technical Debt Quadrant” put forth by Martin Fowler, which attempts to categorise it based on the context and intent:

Technical Debt Quadrant

Source: MartinFowler.com

Final thoughts

Technical debt is common, and not inherently bad. Just like financial debt, it will depend on the purpose that it has been taken up, and plans to clear it. Start-ups battling with pressure to launch their products and get ahead, software companies that have cut-throat competition to deliver fast – development teams usually find themselves having to take on technical debt instead of waiting to launch the products later. In fact, nearly all of the software products in use today have some sort of technical debt.

But no one likes being in debt. Actually, technical staff often find themselves clashing with business executives as they try to emphasise the implications involved when pushing for product launch before the code is completely ready. From a business perspective, it’s all about weighing the trade-offs, when factoring in aspects such as the aspects market situation, competition and consumer needs. So, is technical debt good or bad? It will depend on the context. Look at it this way: just like financial debt, it is not a problem as long as it is manageable. When you exceed your limits and allow the debt to spiral out of control, it can grind your operations to a halt, with the ripple effects cascading through your business.

 

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