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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What Heijunka is & How it Smooths Call Centre Production

The Japanese word Heijunka, pronounced hi-JUNE-kuh means ?levelling? in the sense of balancing workflows. It helps lean organizations shift priorities in the face of fluctuating customer demand. The goal is to have the entire operation working at the same pace throughout, by continuously adjusting the balance between predictability, flexibility, and stability to level out demand.

Henry Ford turned the American motor manufacturing industry upside down by mass-producing his iconic black motor cars on two separate production lines. In this photograph, body shells manufactured upstairs come down a ramp and drop onto a procession of cars almost ready to roll in 1913.

Smoothing Production in the Call Centre Industry

Call Centres work best in small teams, each with a supervisor to take over complex conversations. In the past, these tended to operate in silos with each group in semi-isolation representing a different set of clients. Calls came through to operators the instant the previous ones concluded. By the law of averages, inevitably one had more workload than the rest at a particular point in time as per this example.

Modern telecoms technology makes it possible to switch incoming lines to different call centre teams, provided these are multi-skilled. A central operator controls this manually by observing imbalanced workflows on a visual system called a Heijunka Box. The following example comes from a different industry, and highlights how eight teams share uneven demand for six products.

This departure from building handmade automobiles allowed Henry to move his workforce around to eliminate bottlenecks. For example, if rolls of seat leather arrived late he could send extra hands upstairs to speed up the work there, while simultaneously slowing chassis production. Ford had the further advantage of a virtual monopoly in the affordable car market. He made his cars at the rate that suited him best, with waiting lists extending for months.

A Modern, More Flexible Approach

Forces of open competition and the Six Sigma drive for as-close-to-zero defects dictates a more flexible approach, as embodied in this image published by the Six Sigma organisation. This represents an ideal state. In reality, one force usually has greater influence, for example decreasing stability enforces a more flexible approach.

Years ago, Japanese car manufacturer Toyota moved away from batching in favour of a more customer-centric approach, whereby buyers could customise orders from options held in stock for different variations of the same basic model. The most effective approach lies somewhere between Henry Ford?s inflexibility and Toyota?s openness, subject to the circumstances at the moment.

A Worked Factory Example

The following diagram suggests a practical Heijunka application in a factory producing three colours of identical hats. There are two machines for each option, one or both of which may be running. In the event of a large order for say blue hats, the company has the option of shifting some blue raw material to the red and green lines so to have the entire operation working at a similar rate.

Predictability, Flexibility, and Stability at Call Centre Service

The rate of incoming calls is a moving average characterised by spikes in demand. Since the caller has no knowledge whether high activity advisories are genuine, it is important to service them as quickly as possible. Lean process engineering provides technology to facilitate flexibility. Depending on individual circumstances, each call centre may have its own definition of what constitutes an acceptably stable situation.

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Large scale corporate transformation

Large scale corporate transformation are the necessary actions required to increase performance in an organisation. It leads to greater performance results and greater organisational growth. It is a lasting change and can range from getting new leaders to combining the functions of different departments. It can also involve the introduction of a new phase in the life of an organisation. Large scale corporate transformation can be measured using three variables. The first variable involves determining how deep the change penetrates to all levels of the organisation. The second variable measures how entrenched it becomes in the organisation while the third measure determines the percentage of the organisation covered in the change.

Corporate transformation is essential for a company that seeks to have a greater impact and a longer life in its business sector. The process requires time and resources. The whole establishment needs to support it for success. Not only does the top management need to back it, but stockholders and staff members also need to buy the idea. This is because when the process of corporate transformation hits a barrier, it will take the entire organisation to keep it on course and complete the process. Without the support of everyone, most organisations will not complete the process.

Business transformation in recent times has begun to combine finance, HR and IT departments into one functioning piece of an organisation. This has resulted in leaner, faster, and more efficient corporate entities that produce high results and has a greater impact in its overall functioning. These three key departments are the backbone of any organisation, and the combination of the three creates an efficient organisation that translates into high performance results.

One crucial aspect of large scale corporate transformation is IT transformation, which entails the entire overhaul of any organisation’s technology systems. It adopts a more efficient platform that enhances its overall operation. IT transformation involves the use of Service Oriented Architecture (SOA) and open systems. This process is the revamping of the existing technology used to support the organisation and is critical for aligning the business functions to the mission of the organization. It touches on the current hardware and software and how they can best be improved upon for greater results. This process is necessary in the entire business transformation.

The question that needs to be addressed is how any organisation can make this process successful. First, it requires the understanding that it is not just a goal to be achieved, but a new way of thinking embraced by the entire organisation. Secondly, the leadership in place needs to be fully involved and dedicated to the process and to realise that it takes time and effort to complete such a mission. There also needs to be flexibility and adaptability in order to learn from mistakes and keep moving forward. Constant communication is also critical to ensure that everyone involved understands the current stage and the next steps to be done. Change is the only constant and is necessary for progress and success.

Saving Energy Step 4 – Breathing Life into the Project

Today we consider the fourth step on the road to energy saving, when we introduce key contributors who will pull it all together. We have been on quite a journey. We started by developing a management system and then followed up with practical improvements, while challenging the assumptions behind the energy bills we may have paid unchallenged in the past.

After we knock off the big-ticket savings, managing energy becomes a process of improvement characterised by smaller increments. Kaizen is the classic model and it includes everybody in the organization from the janitor to the CEO. I inverted the pyramid deliberately, because ideas deserve considering no matter where the originator parks in the company yard.

People ? our people ?are truly central to the process. Energy adds extra leverage to their efforts, keeps them warm in winter, cool in summer and powers up the ovens in the company canteen. They are brimming over with ideas because that is the nature of being human. The best managers are those who release this potential and participate in its flowering,

It is important not to threaten job security. So many savings-driven initiatives have ended in job losses that people on the shop floor automatically suspect another round. Shrinking carbon footprints is about making the world a better place for everyone. We become more effective when we turn ?increasing profit? into making the enterprise sustainable in itself.

Engaging employees is more than office circulars and speeches at the Christmas Party. Organizations are organic places where trust grows slowly but conflict can flare in a moment. Before involving your people in your energy ?kaizan? make sure your words and intentions overlap perfectly. You will be amazed at the power you unlock in your people.

The best way I know of doing this is through your health and safety structure, which then becomes your environment, health and safety structure EHS. As you explore this idea at safety committees you find these things overlap, in the sense of creating people-centric environments at work and home.

That said, there is no magic formula for achieving employee engagement. The fact that people universally want a cleaner planet is the power to tap into. One way to form a team is to create one artificially and give it a task. The other is to work together towards a shared objective. Which one do you prefer?

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