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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Article 8 of the EU Energy Efficiency Directive ? Orientation

Following in-depth discussion of the UK?s ESOS response, we decided to backtrack to the source, especially since every EU member is facing similar challenges. The core purpose of the directive is to place a pair of obligations on member states. These are

  1. To promote the availability of energy audits among final customers in all sectors, and;
  2. To ensure that enterprises that are not SMEs carry out energy audits at least every four years.

Given the ability for business to look twice at every piece of legislation it considers unproductive, the Brussels legislators took care to define what constitutes an enterprise larger than an SME.

Definition of a Large Undertaking

A large undertaking meets one or both of the following conditions:

  1. It employs 250 or more people
  2. Its annual turnover is more than ?50 million and its balance sheet total exceeds ?43 million

Rules for Energy Audits

If accredited / qualified in-house specialists are unavailable then independent experts should supervise audits. The talent shortage seems common to many EU businesses. In hindsight, the Union could have ramped up slower, especially since the first compliance date of 5 December 2015 does not leave much swing room.

ecoVaro doubts there was a viable alternative, given the urgent imperative to beat back the scourge of carbon that is threatening the viability of our planet. The legislators must have been of a similar mind when laying down the guidelines. Witness for example the requirement that penalties be ?effective, proportionate and dissuasive?.

In order to be compliant, an energy audit must

  1. Be based on twelve months of verifiable data that is
    • over a continuous period beginning no more than 24 months before the beginning of the energy audit, and;
    • identifies energy saving opportunities including paths to their achievement
  2. Analyse the participant’s energy consumption and energy efficiency
  3. Have not been used as the basis for an energy audit in a previous compliance period

Measurement of current status and progress tracing are at the core of energy saving and good governance generally. EcoVaro has a powerhouse of software tools available on the cloud to help project teams save time and money.

A Definitive List of the Business Benefits of Cloud Computing ? Part 3

Strengthens business continuity/disaster recovery capabilities

Today’s business landscape calls for companies to have reliable business continuity and disaster recovery capabilities. After all, when the system goes down, customers and even employees would rarely ask ‘why‘ or ‘what happened‘ but instead go directly to the ‘how soon can we get back up‘ part.

So unless they’ve been struck by the same unforeseen disaster your business is also experiencing, a couple of hours downtime is plenty enough for most of these people. What’s worse is when they simply don’t wait until they get access again and just go to other providers that can offer the same services. In short, your inability to provide continuous IT and business services could translate to lost opportunities which your competition would only be too willing to gain. And that’s not even counting the possibility of losing essential data and other potential negative impact that critical IT failure can bring about.

The answer to avoiding such a scenario is of course, having a sound business continuity and disaster recovery plan in place. But this is actually easier said than done.

Traditionally, setting up a business continuity plan entailed some tedious procedures in addition to very costly infrastructure. We’re talking here about acquiring and maintaining practically a replication of the hardware infrastructure and environments currently existing for business-critical systems and data. Note that these mirror systems should be set-up, housed, and maintained in a remote facility or location.

Making the deployment even more complex is the constant need to update the data in storage as well as keep software applications in sync between the system in use and the one on standby mode. This process would involve the physical transfer of data and syncing of applications, which is cumbersome and again, expensive.

While large enterprises would not even think twice about having to spend so much to ensure that operations would never come to a grinding halt, most small and mid-sized organisations would not have the required financial means for them to even start considering this option. Often, the bulk of their disaster recovery plan would simply consist of some tape backups, and a lot of hoping that they would never have to suffer from any outage or IT failure.

But all that can be changed with the arrival of cloud computing.

A cloud strategy offers an affordable solution for business continuity and disaster recovery for SMBs with limited resources and even big companies trying to minimise expenses by looking for alternative options.

A reliable service provider would already have the required infrastructure and software vital to a viable BC/DR plan and complete with the appropriate security measures. Organisations need not spend upfront for these facilities, but get to benefit from having updated data backup and a virtualised mirror system that would allow them to quickly get back up in the event of an outage or catastrophic disaster.

When looking to the cloud for a cost-effective BC/DR plan however, it’s worth keeping in mind that not all cloud providers are created equal. That’s why businesses also have many important factors to take into account before signing cloud contracts.

Yes, provision for continuity and and taking necessary precautions against outages are inherent in the cloud service itself, but you’d be surprised how many of these providers don’t actually take responsibility for service interruption. To give organisations some assurance of the cloud company’s capacity for continued service, contracts should stipulate availability guarantees and liability for downtime that the provider is willing to answer for.

Once these relevant issues are ironed out however, it’s easy for business to see how cloud-based data storage and computing can significantly lower the costs involved for SMB BC/DR while greatly improving efficiency, mobility, and collaboration capabilities.

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ISO in Energy management

Every industry has its own set levels of quality that are considered acceptable or desirable. Energy performance like any other field is governed by some set standards. These differ across regions but international standards do exist.

ISO 50001 is the international energy standard applicable to both large and small organisations irrespective of geographical, cultural or social conditions. It outlines the best energy management practices that are considered to be the best by specifying that an organisation must integrate an energy management system and institute an energy policy, objectives, targets, and action plans taking into account legal requirements and information related to significant energy use. The energy standard is applicable to organisations.

What’s the importance of attaining energy certification?

ISO certification in any industry is a demonstration of quality or that a service or product meets the expected service standards. In energy management, ISO certification is a demonstration that an organisation or company has implemented sustainable energy management systems, completed a baseline of energy use and, is committed to continuously improve its energy performance. In addition, ISO certification assists organisations in the following ways:

? Organisations are able to optimise the existing energy-consuming assets

? Offers guidance on bench-marking, measuring, documenting, and reporting energy intensity improvements and their projected impact on reducing GHG emissions

? Creates transparency and facilitates communication on the management of energy resources

? Promotes energy management best practices and reinforces good energy management behaviours

? Assists facilities in evaluating and prioritising the implementation of new energy-efficient technologies

? Provides a framework for promoting energy efficiency throughout the supply chain

? Facilitates energy management improvements in the context of GHG emission reduction projects: The reduction of carbon emissions means therefore an organisation is able to meet government carbon reduction targets by demonstrating environmental credentials. The accruing benefits are many, ranging from increased investor confidence to more tender opportunities

Energy management software plays a vital role in helping organisations comply with energy standards through improved performance across the various functions in an organisation.

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