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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Keys to Successful Matrix Management

Matrix management, in itself, is a breakthrough concept. In fact, there are a lot of organizations today that became successful when they implemented this management technique. However, there are also organizations that started it but failed. And eventually abandoned it in the end.

Looking at these scenarios, we can say that when you implement matrix management in your organisation, two things can happen – you either succeed or fail. And there?s nothing in between. The truth is, the effectiveness of matrix management lies in your hands and in your implementation. To ensure that you achieve your desired results, recognise these essential keys to successful matrix management.

Establish Performance Goals and Metrics

This should be done as soon as the team is formed, at the beginning of the year or during the process of setting organisational objectives. Whenever it is, the most important thing is that each team player understands the objectives and metrics to which their performances will be evaluated. This ensures that everyone is looking at the same set of objectives as they carry out their individual tasks.

Define Roles and Responsibilities

One pitfall of matrix management is its internal complexity. Awareness of this limitation teaches you to clearly define the roles and responsibilities of the team players up front. Basically, there are three principal sets of roles that should be explained vividly ? the matrix leader, matrix managers and the matrixed employees. It is important to discuss all the possible details on these roles, as well as their specific responsibilities, to keep track of each other?s participation in the projects of the organisation.

One effective tool to facilitate this discussion is through the RACI chart – Who is Responsible? Who is Accountable? Who should be Consulted? Who will Implement? With this, clarification of roles and responsibilities would be more efficient.

When roles are already clearly defined, each participant should review their job descriptions and key performance metrics. This is to make sure that the roles and responsibilities expected of you integrates consistently with your job in the organisation, as a whole.

Manage Deadlines

In matrix management, the employees report to several managers. They will likely have multiple deadlines to attend to and accomplish. There might even be conflicts from one deadline to another. Hence, each should learn how to schedule and prioritise their tasks. Time management and action programs should be incorporated to keep the grace under pressure.

Deliver Clear Communication

Another pitfall of matrix management is heightened conflict. To avoid unrealistic expectations, the matrix leaders and managers should communicate decisions and information clearly to their subordinates, vice versa. It would help if everyone will find time to meet regularly or send timely reports on progress.

Empower Diversity

Knowledge, working styles, opinions, skills and talents are diverse in a matrix organisation. Knowing this fact, each should understand, appreciate and empower the learning opportunities that this diversity presents. Trust is important. Respect to each other?s opinions is vital. And acknowledgement of differing viewpoints is crucial.

The impetus of matrix management is the same ? mobilise the organisation’s resources and skills to cope with the fast-paced changes in the environment. So, maximise the benefits of matrix management as you consider these essential keys to its successful implementation.

How Bombardier Inc. scored a Bulls Eye

When travelling anywhere in the world on land, sea or air, chances are, you will travel courtesy of something made by aerospace and transportation company Bombardier based in Montreal, Canada. In 2009, it set itself the goal of carbon neutrality by 2020. In other words, it hoped to remove as much carbon dioxide from the atmosphere as it was putting in.

By 2012, Bombardier concluded it was not going to become carbon neutral by 2020 at its current rate of progress. It discounted purchasing carbon offsets because it believed it would serve its interests better by introducing new energy-saving products to market faster. That way, it would achieve its objectives vicariously through the decisions of its customers. But that was not all that forward-thinking Bombardier did. It also set itself the following inward-facing objectives:

  • Reduce carbon footprint through efficient use of energy and less emissions
  • Involve the Bombardier workforce to raise awareness of behaving responsibly
  • Implement sustainable initiatives to further reduce the company carbon footprint

Specific Examples

At its Wichita site, Bombardier (a) fitted a white roof and insulation reducing summer energy consumption by 40%, (b) added an energy recovery wheel to balance air circulation, and (c) introduced skylights with integrated controllers to lower energy consumption by lighting.

At Mirabel, it enhanced the flue-gas management system by adding a pressure differential damper.

At Belfast, Bombardier (a) optimised HVAC systems to reduce pressure on chilling and air-handling plants, (b) installed solar panels on the roof, and (c) obtained approval for a waste-to-energy plant that will convert 120,000 tonnes of non-recyclable waste material annually.

By the end of 2013, Bombardier had already beaten its immediate targets by:

  • Reducing energy consumption by 11% against 2009
  • Reducing greenhouse gas emission by 23% against 2009
  • Reducing water consumption by 6% against 2012

Future Plans

Bombardier will never stop striving to reach its goal of carbon neutrality by 2020. It has a number of other projects in the pipeline waiting for scarce resources to fund them. During 2014, it continued with energy efficient upgrades at its French, Hungarian, Polish, Swiss, and UK plants.

These include consumption monitoring systems, LEDs for workshop lighting, new heating systems, and outdoor energy-saving tower lighting. The monitoring is important because it helps Bombardier focus effort, and provides measured proof of progress.

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Can you do away with the Project Initiation Meeting?

Project initiation meetings are often skipped to fast-track projects. Once a sponsor is found, organisations go straight to project planning and execution. But based on our own experience, holding a project initiation meeting can actually eliminate many issues that may crop up in the future and hence may speed things up instead in the long run.

It is in the project initiation meeting where your project objectives and scope are clarified and all stakeholders are brought to the same page. Project sponsors and stakeholders will have to know in a nutshell what is needed from them, what the possible risks are, what different resources are required, and so on. So that, when it’s time to proceed to the next phase, everyone is already in-sync.

So what are taken up in such a meeting? Perhaps an actual example can help. Sometime in the past, we set out to work on an eCommerce website project. After conducting the project initiation meeting, these were some of the things we were able to accomplish:

  • Identified deliverables e.g. site design, interface to payment system, etc.
  • Come up with the project phases
  • Agreed what should be in and out of scope
  • Defined the acceptance test criteria
  • Identified possible risks
  • Identified the possible training and documentation work needed
  • Established whether any analysis was required, e.g. as with regards to payment interfaces
  • Formulated disaster recovery plans
  • Defined roles and responsibilities
  • Drafted timelines and due dates

Aren’t these covered in project planning? If the project is a big one, the answer is no. In a large project, project planning is a much more exhaustive activity. In a project initiation meeting, only the basic framework is defined.

Some questions may still remain unanswered after a project initiation meeting, but at least you already know what answers you need to look for. In the example we gave earlier, we left the meeting knowing that we needed:

  • a list of all necessary hardware to estimate the costs
  • to identify possible dependencies we might have with third parties
  • to identify what software had to be bought and what skills we needed to hire

When it was time to proceed to project planning, everyone involved already knew what direction we were taking. In effect, by not skipping the project initiation meeting, we were able to avoid many potential obstacles.

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