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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Technology and process improvement

Tightening organisational flow to improve productivity and minimise costs is a growing concern for many businesses post the Global Financial Crisis. Businesses can no longer afford to waste time and personnel on inefficient processes. Organisations using either Six Sigma or Lean techniques better manage their existing resources to maximise product out-put. Both of these techniques involve considerable evaluation of current processes.

What is Six Sigma?

Six Sigma is an organisational management strategy that evaluates processes for variation. In the Six Sigma model, variation equates waste. Eliminating variation for customer fulfilment allows a business to better serve the end-user. In this thought model, the only way to streamline processes is to use statistical data. Each part of a process must be carefully recorded and analysed for variation and potential improvements. The heart of the strategy embodied by Six Sigma is mathematical. Every process is subject to mathematical analysis and this allows for the most effective problem solving.

What is a Lean Model?

Lean businesses do not rely on mathematical models for improvement. Instead, the focus is on reducing steps in the customer delivery cycle, which do not add value to the final deliverable. For example, maintaining excess inventory or dealing with shortages would both be examples of waste behaviour. Businesses that operate using Lean strategies have strong cash flow cycles. One of the best and most famous examples of Lean in action is the Toyota Production System (TPS). In this system, not only is inventory minimised, but physical movement for employees also remains sharply controlled. Employees are able to reach everything needed to accomplish their tasks, without leaving the immediate area. By reducing the amount of movement needed to work, companies also remove wasted employee time.

Industry Applications for Lean and Six Sigma

Lean businesses reduce the number of steps between order and delivery. The less inventory on hand, the less it costs a business to operate. In industries where it is possible to create to order, Lean thinking offers significant advantages. Lean is best utilised in mature businesses. New companies, operating on a youthful model, may not be able to identify wasteful processes. Six Sigma has shown its value across industries through several evolution’s. Its focus on quality of process makes it a good choice for even brand new businesses. The best use is the combination of the two strategies. With the Lean focus on speed and the Six Sigma focus on quality combined, the two organisational processes create synergy. By itself, Lean does not help create stable, repeating success. Six Sigma does not help increase speed and reduce non value-added behaviours. Combined, these two strategies offer incredible value to every business in cost savings.

Using Technology to Implement Lean Six Sigma

Automation processes represent an opportunity for businesses to implement a combination of both Lean and Six Sigma strategies. Any technology that replaces the need for direct human oversight reduces costs and increases productivity. A few examples of potentially cost saving IT solutions include document scanning, the Internet, and automated workflow systems.

  • Document Scanning – Reducing dependency on paper copies follows both Lean and Six Sigma strategies. It is a Lean addition in that it allows employees to access documents instantly from any physical location. It is Six Sigma compliant in that it allows a reduction on process variation, since there is no bottleneck on the flow of information.
  • The Internet – The automation potential offered by the Internet is limitless. Now, businesses can enter orders, manage logistics and perform customer service activities from anywhere, through a hosted portal. With instant access to corporate processes from anywhere, businesses can manage workflow globally, allowing them to realise cost savings from decentralisation.
  • Automated Work Systems – One of the identified areas of waste in any business is processing time. The faster orders are processed and delivered, the greater the profits for the company and the less the expense per order. When orders sit waiting for attention, they represent lost productivity and waste. Automated work systems monitor workflow and alert users when an item sits longer than normal. These systems can also reroute work to an available employee when the original worker is tied up.

Each of these IT solutions provides a method for businesses to either reduce the number of steps in a process or improve the quality of the process for improved customer service.

Identifying Areas for Lean Six Sigma Implementation

Knowing that improved processes result in improved profits, identifying areas for improvement is the next step. There are several techniques for creating tighter processes with less waste and higher quality. Value Stream Mapping helps business owners and managers identify areas of waste by providing a visual representation of the total process stream. Instead of improving single areas for minimal increases in productivity, VSM shows the entire business structure and flow, allowing management to target each area of slow down for maximum improvement in all areas.

Seeing the areas of waste helps management better determine how processes should work to best obtain the desired outcomes. Adding in automated processes helps with improved process management, when put in place with a complete understanding of current systems and their weaknesses. Start with mapping and gain a bird’s-eye view of the situation, in order to make the changes needed for improvement.

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Will UK Retailers Skim the Cream with ESOS?

The British Retail Consortium (BRC) was quick out on the starting blocks with an ambitious plan to cut energy costs by 25% in 5 years. Their ?25-in-5? initiative is chasing a target of ?4.4 billion savings during the duration. Part of this program involves ?cutting a path through a complex and inaccessible policy landscape?. BRC believes this drawback is making its members think twice about making energy efficiency investments.

The UK?s sprawling network of grocers, department stores and malls is the nation?s second most hungry energy customer, having spent ?3.3 billion on it in 2013 when it accounted for almost 20% of carbon released. If you think that sounds bad, it purchased double that amount in 2005. However the consortium believes there is still more to come.

It bases this assumption on the push effect of UK energy rates increasing by a quarter during the duration of the project. ?So it makes sense to be investing in energy efficiency rather than paying bills,? Andrew Bolitho (property, energy, and transport policy adviser) told Business Green. The numbers mentioned exclude third party transport and distribution networks not under the British Retail Consortium umbrella.

The ?complex and inaccessible policy landscape? is the reflection of UK legislators not tidying up as they go along. BRC cites a ?vast number of policies ? spreading confusion, undermining investment and making it harder to raise capital?. The prime culprits are Britain?s CRC Energy Efficient Scheme (previously Carbon Reduction Commitment) which publishes league tables and ESOS. Andrew Bolitho believes this duality is driving confused investors away.

The British Retail Consortium is at pains to point out that this is not about watering things down, but making it simpler for participating companies to report on energy matters at a single point. It will soon go live with its own information hub providing information for retailers wishing to measure consumption at critical points, assemble the bigger picture and implement best practice.

Ecovaro agrees with Andrew Bolitho that lowering energy demand and cutting carbon is not just about technology. We can do much in terms of changing attitudes and providing refresher training and this does not have to cost that much. Studies have shown repeatedly that there is huge benefit in inviting employees to cross over to our side. In fact, they may already be on board to an extent that may surprise.

Vendor Selection

When shopping for an IT solution for your enterprise, there are two things you should scrutinise: the product (or service) itself and its vendor. Many times, companies overlook the importance of the latter, giving the reason that “it’s only the product we need”.

Wrong.

What about after-sales technical support and training? Ok, so you have an in-house team with the required competency for that IT solution in question… not that I believe it’s reasonable basis to pass up on the expertise that the vendor can provide. How about upgrades, patches, and documentation?

Still unperturbed? Here’s one factor that you may not have started to consider – What happens to your product if the vendor goes bankrupt or gets swallowed by a merger and acquisition? Surely, you no longer believe this is far from possible, do you?

But how are you supposed to know the financial stability of each vendor or whether it is an acquisition target? Well, you can either conduct your own research or you can leave that up to us. Part of our job includes not only establishing linkages in the industry but also being in-the-know on such relevant information.

Evaluation of Business Needs

You can’t separate vendor selection from the process of choosing the desired IT tool. That’s why our vendor selection services starts by defining exactly what your business needs are.

Once we’ve pinned down your needs, we can then narrow down the list of possible IT solutions. Only then can we proceed with the main vendor selection process.

Have you ever been caught in a situation wherein you thought you knew what you wanted, only to end up realising it’s not what you were looking for after all? We’re here to make sure you don’t get caught in that kind of situation when choosing an enterprise-class IT solution.

With the TCO (total cost of ownership) of such solutions typically running up to hundreds of thousands of euros, you can’t afford to arrive at what you really want by way of trial and error.

These are the things you stand to benefit the moment we start working with you:

  • Thorough assessment of your IT needs. We’ll consult the people in your organisation who’ll be affected the most in order to obtain a clear picture of what your specific needs really are. Most IT solution purchases are made with very little consultation that, after installation, many of the end users don’t benefit at all.
  • Minimal interruption during assessment. As with all our other services, we see to it that the interruptions we make are absolutely necessary. So the moment we start with our work, you can still continue with yours.
  • Insightful suggestions of the required IT solution. You still know your business better. So even after we’ve gone through the assessment and given our recommendations, the decision as to what IT tool should be pursued will still be up to you. The difference now is, you’ll be making a decision based on expertly gathered information put forward in an insightful proposal.

Request and Evaluation of Vendor Proposals

With so many IT solutions companies mushrooming, it is becoming more difficult to keep track of them, their specialities, strengths, and weaknesses.

Companies selling best-of-breed products may be relatively easy to spot. But there are also other attributes that are equally important but not as well publicised. For instance, which companies offer better quality management philosophies? Which companies have strategic visions running parallel to yours? Which of them possess implementation capabilities that can cater to your rapidly growing IT requirements?

Vendors who answer positively to these queries need to be given the appropriate importance in the selection process. We see to it that these and other relevant attributes are factored into our scorecards and evaluation processes.

These are the things you can look forward to when you grant us the opportunity to serve you.

  • Experience is a vital item in our vendor selection criteria. Our vast knowledge of the reliable players in the industry will lead you to experienced vendors who can hit the ground running from day one and continue with the same vigour onward.
  • We can help you draw positive response for each of your Request For Proposals (RFPs) or Request For Information (RFIs). Did you expect these vendors to be enthusiastic in sending out proposals each time you asked them to? Think again. You’ll have to persuade them first of your sincerity to become a potential customer. With our help, your RFPs will make preferred vendors see “opportunity” written all over.
  • No need to go “Eany, meeny, miny, moe”. Deciding which vendors should move up in the selection process can take up a lot of time if you don’t know which criterion should be given more weight. Our scorecards are designed to collect the most relevant information and to generate results that will help you decide on these matters at a glance.

Interview, Negotiation, and Monitoring

As soon as you start getting positive response to your Request For Proposals, the interview process should be next. It’s at this point that vendors can present and highlight their strengths while we try to glean as much information of their true capabilities as well as their dedication to the project.

Some companies can provide proof-of-concepts and we may require them as part of the interview process. This will not only give us a better idea as with regards to their product’s capabilities, but also to their level of expertise on the solution in question.

  • We’ll help you set up the interview process and organise the evaluation committee. Members of the committee will typically include representatives from each department that will be affected by the new technology, which we would have already identified during our Evaluation of Business Needs.
  • Since our scorecards are designed to expedite the filtering and selection process, you may eventually be able to choose the finalists yourself. However, in the event that two or more vendors turn out evenly matched, we’ll help you identify the better company.
  • We’re very familiar with the price ranges of various IT solutions, including the effects on price of certain variables. As such, we can tell you whether a product’s price tag is justified or not.
  • Our exceptional familiarity on both the IT industry and the entire negotiation processes itself will give you the edge when it’s time for us to haggle for the best bang for the buck.
  • After the contract is awarded, we’ll even be on hand to monitor whether deliverables are handed over and milestones are achieved as promised.

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