How To Get Started with your IT Compliance Efforts for SOX

There’s no question about it. For many of you top executives in the corporate world, all roads leading to a brighter future have to go through SOX compliance. And because the business processes that contribute to financial reporting (the crux of the Sarbanes-Oxley Act) are now highly reliant on IT systems, it is important to focus a good part of your attention there.

It is a long and arduous path to IT compliance, so if you don’t want your company to fall by the wayside due to inefficient utilisation of resources, it is important to set out with a plan on hand. What we have here are some vital information that will guide you in putting together a sound plan for SOX compliance of your company?s IT systems.

Why focus on IT systems for SOX compliance?

We’ll get to that. But first, let’s take up the specific portions of the Sarbanes-Oxley Act that affect information technology. These portions can be found in Section 302 and Section 404 of the act.

In simplified form, Section 302 grants the SEC (Securities and Exchange Commission) authority to come up with rules requiring you, CEOs and CFOs, to certify in each annual or quarterly financial report the following:

  • that you have reviewed the report;
  • that based on your knowledge, the report does not contain anything or leave out anything that would render it misleading;
  • that based on your knowledge, all financial information in the report fairly represent the financial conditions of the company;
  • that you are responsible for establishing internal controls over financial reporting; and
  • that you have assessed the effectiveness of the internal controls.

Similarly, Section 404, stated in simplified form, allows the SEC to come up with rules requiring you, CEOs and CFOs, to add an internal control report to each annual financial report stating that you are responsible for establishing internal controls over financial reporting.

You are also required to assess the effectiveness of those controls and to have a public accounting firm to attest to your assessment based upon standards adopted by the Public Company Accounting Oversight Board (PCAOB).

While there is no mention of IT systems, IT systems now play a significant role in financial reporting. Practically all of the data you need for your financial reports are stored, retrieved and processed on IT systems, so you really have to include them in your SOX compliance initiatives and establish controls on them.

Now that that’s settled, your next question could very well be: How do you know what controls to install and whether those controls are already sufficient to achieve compliance?

Finding a suitable guide for IT compliance

The two bodies responsible for setting rules and standards dealing with SOX, SEC and PCAOB, point to a well-established control framework for guidance – COSO. This framework was drafted by the Committee of Sponsoring Organisations of the Treadway Commission (COSO) and is the most widely accepted control framework in the business world.

However, while COSO is a tested and proven framework, it is more suitable for general controls. What we recommend is a widely-used control framework that aligns well with COSO but also caters to the more technical features and issues that come with IT systems.

Taking into consideration those qualifiers, we recommend COBIT. COBIT features a well thought out collection of IT-related control objectives grouped into four domains: Plan and Organise (PO), Acquire and Implement (AI), Deliver and Support (DS), and Monitor and Evaluate (ME). The document also includes maturity models, performance goals and metrics, and activity goals.

A few examples of COBIt’s detailed control objectives are:

DS4.2 – IT Continuity Plans
DS4.9 – Offsite Backup Storage
DS5.4 – User Account Management
DS5.8 – Cryptographic Key Management
DS5.10 – Network Security
DS5.11 – Exchange of Sensitive Data

By those titles alone, you can see that the framework is specifically designed for IT. But the document is quite extensive and, chances are, you won’t need all of the items detailed there. Furthermore, don’t expect COBIT to specify a control solution controls for every control objective. For example, throughout the control objective DS4 (Ensure Continuous Service), you won’t find any mention of virtualisation, which is common in any modern business continuity solution.

Basically, COBIT will tell you what you need to attain in order to achieve effective governance, management and control, but you’ll have to pick the solution best suited to reach that level of attainment.

Articles highly relevant to the one you just read:

Month End Accounting The Way It Should Be Today
Spreadsheet Woes ? Burden in SOX Compliance and Other Regulations
Spreadsheet Woes ? Limited Features For Easy Adoption of a Control Framework
How Internal Auditors Can Win The War Against Spreadsheet Fraud

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5 Numbers showing why the Time to Invest in eCommerce in the UK is Now

A decade or two ago, you might have already had the urge to invest in eCommerce. But astute as you are, you must have decided to wait for the right time and perhaps the right place to do it. That time has come. And the right place to do it? Try the United Kingdom.

Here’s why:

1. ?100 billion worth to the UK economy

A report conducted by US-based BCG (Boston Consulting Group) showed that Internet-based business in the UK reached ?100 billion in 2009. That translated to 7.2% of the country’s GDP that year, making it bigger than industries like construction, education, and health & social work, and even slightly bigger than agriculture, hotels & restaurants, and mining, combined. Click here to see the comparison shown as a graph.

?100 billion?is certainly huge, but?the market potential of the Internet in UK is even made more evident if you also look at the numbers based on amount spent per capita…

2. # 1 in per capita spending

According to IMRG (Interactive Media in Retail Group), “the UK’s per capita spend of ?1333 (?1108) per annum” is number one in the world. This shows that people from the United Kingdom are more willing to buy goods from the Internet than other people on the planet. And this alone should tell you why UK is the best place for e-commerce.

But while you’re still pondering whether now is really the best time to invest, bear in mind that competitors who have gone to the Internet before you are already thinking of expanding …

3. 1.5 million workers in Internet retailing by 2015

Last year (2011), the number of people employed in UK e-businesses was about 730,000. While conducting its second annual e-Jobs index in 2011, IMRG (Interactive Media in Retail Group) found out that it was largely due to a rise in employment in 63% of e-businesses. The study also showed that 60% of e-businesses were also planning to beef up their employees within a year’s time.

While other sectors are shrinking their ?workforce, businesses on the Internet are growing theirs. Were they just speculating? Perhaps not…

4. 50% of parsels during 2016 pre-Christmas peak will come from e-commerce

Last year (2011), parcels coming from e-commerce accounted for 37% of all items sent through UK couriers during the November-December stretch. That volume from e-commerce was 15% higher than the previous year. This remarkable climb, which was reported by Global Freight Solutions (GFS), shows the growing confidence of customers when it comes to buying products online.

If this rate continues, items from e-commerce will easily comprise 50% of parcels by 2016. Chances this rate will continue? Let’s go to number 5 and you be the judge.

5. 66% of all adults made online purchases in 2011

A statistical bulletin published by the ?Office for National Statistics revealed that 32 million people made online purchases in 2011. That actually comprises 66% of all adults in the UK. Significant as that may seem, what is really striking is that that figure used to be 62% in 2010. So again, this proves that the number of people who buy products and services online is steadily growing.

If you really think about it, these statistics should not be surprising. The smartphone is now practically the default mobile device of anyone who owns a mobile phone. And then of course there are laptops and tablets.

With these devices on hand, coupled with the ever growing number of WiFi hotspots and telecommunications bandwidth, gaining access to the Web has never been easier.?It can be done practically anytime, anywhere.

This makes it so easy for people to search for products, compare competing brands, and eventually make a purchase from home, the office, on the terminal, or on the train.

Related post:

Integrated e-commerce ? The right way to do extend your business online

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What Sub-Metering did for Nissan in Tennessee

When Nissan built its motor manufacturing plant in Smyrna 30 years ago, the 5.9 million square-foot factory employing over 8,000 people was state of art. After the 2005 hurricane season sky-rocketed energy prices, the energy team looked beyond efficient lighting at the more important aspect of utility usage in the plant itself. Let’s examine how they went about sub-metering and what it gained for them.

The Nissan energy team faced three challenges as they began their study. They had a rudimentary high-level data collection system (NEMAC) that was so primitive they had to transfer the data to spread-sheets to analyse it. To compound this, the engineering staff were focused on the priority of getting cars faster through the line. Finally, they faced the daunting task of making modifications to reticulation systems without affecting manufacturing throughput. But where to start?

The energy team chose the route of collaboration with assembly and maintenance people as they began the initial phase of tracking down existing meters and detecting gaps. They installed most additional equipment during normal service outages. Exceptions were treated as minor jobs to be done when convenient. Their next step was to connect the additional meters to their ageing NEMAC, and learn how to use it properly for the first time.

Although this was a cranky solution, it had the advantage of not calling for additional funding which would have caused delays. However operations personnel were concerned that energy-saving shutdowns between shifts and over weekends could cause false starts. ?We’ve already squeezed the lemon dry,? they seemed to say. ?What makes you think there?s more to come??

The energy team had a lucky break when they stumbled into an opportunity to prove their point early into implementation. They spotted a four-hourly power consumption spike they knew was worth examining. They traced this to an air dryer that was set to cyclical operation because it lacked a dew-point sensor. The company recovered the $1,500 this cost to fix, in an amazing 6 weeks.

Suitably encouraged and now supported by the operating and maintenance departments, the Smyrna energy team expanded their project to empower operating staff to adjust production schedules to optimise energy use, and maintenance staff to detect machines that were running without output value. The ongoing savings are significant and levels of shop floor staff motivation are higher.

Let’s leave the final word to the energy team facilitator who says, ?The only disadvantage of sub-metering is that now we can’t imagine doing without it.?

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Implementing Matrix Management

Matrix management is a culture change. More than the hierarchical structures, lines of responsibilities, modes of communication and channels of decision-making, it is a concept that needs to be planned ahead and managed appropriately over time.

Implementing matrix management to any organization can be confusing. It is essential to ensure that it fits right to your business strategies, skills and competencies. With this, realizing matrix management should not be taken lightly. Careful stages should be considered, instead.

Here are the steps to proper implementation of matrix management:

Consider Your Business Context

You need to evaluate your organisation to analyse what are your development needs with regards to skills, products, services and market environment. This will help you decide on what type of matrix structure you will apply in your organisation. Consider the following questions in building up your context:

  • What is our strategy?
  • Where are the demands in our business?
  • What are the structures that our competitors currently employ?
  • What are the talents that my people possess?
  • What are other business organizations doing?

Set Your Implementation Scope

Next, you need to define the parameter and set the scope of your implementation. What area in your business do you think matrix management will successfully work? There are several things that you need to consider in setting your scope. You have to make sure that it works well with your overall business strategies, that it can be excellently communicated and easily understood. Also, you must ensure that you acquire the necessary talents and skills in the business to deliver the new system of responsibilities.

Implement the New Structure

When you have already decided what structure type you will implement, you are ready to give it a go. You will need to establish new communication channels so you can monitor the progress and receive feedback effectively.

Here?s how to apply the matrix structure:

  • Highlight your development needs
  • Define roles based on outputs and not inputs
  • Line up procedures and systems to support the structure and the behaviour that comes with it.
  • Invest in training and development
  • Support the key people in the structure by coaching them to better adapt in changes
  • Communicate regularly
  • Monitor progress and make necessary adjustments

Review the Matrix Structure, Roles and Responsibilities

Organisations that successfully implement matrix management adapt to the changes in their environment. With this, they do regular evaluations to highlight the need for changes and revisions. The review can either focus on the structure only or to the entire process as a whole. The results can alter the structure, the roles involved and the responsibilities taken.

The process of implementing matrix management follows a step-by step method. Each stage is equally important with the rest. Hence, if you plan to exploit it in your organisation, you have to recognise the purpose of each step and follow it appropriately. Balance is the key. And when you achieve stability in matrix management, amidst the complex changes in the world of business, then your organisational success is just around the corner.

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