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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How Armstrong World Industries is going Cradle-to-Cradle

The Cradle-to-Cradle concept holds that human effort must be biometric, in other words enrich the environment within which it functions as opposed to breaking it down. This means manufacturing must be holistic in the sense that everything is reusable and nothing is destroyed. Armstrong World Industries was the first global mineral ceiling tile manufacturer to achieve Cradle-to-Cradle certification. We decided to take a closer look at how they achieved this.

Armstrong Worldwide Industries has five plants in the UK alone. These produce an annual turnover of ?2.7 billion. They have been making ceilings for more than 150 years. Fifteen years ago and way ahead of the curve it started recycling, and has maintained a policy of not charging contractors for waste ever since. Along the way, it developed a product that can be re-used indefinitely.

The Challenge

Going green must also be commercially sustainable. In Armstrong?s case, it faced a rise in landfill tax from ?8 per tonne per year to ?80 per tonne per year. This turned the financial cost of waste from a nuisance to a threat. It calculated that recycling one tonne of ceiling materials would:

  • Eliminate 456kg of CO2 equivalents by saving 1,390 kWh of electricity
  • Preserve 11 tons of virgin material and save 1,892 gallons of potable water

They hoped to extend their own recycling project by asking demolition and strip-out contractors to join it, so they could reprocess their scrap as new batches of tiles too.

The Achievement

As things stand today, an Armstrong ceiling tile now contains an average of 82% recycled content. Indeed, if they could find more ceilings to recycle this could reach 100%. In the past two years alone, Armstrong Worldwide Industries UK has saved 130,399m? of greenfield from landfill, being the equivalent of 520 skips that would otherwise have cost contractors over ?88,000 to dispose of.

The Broader Context

Armstrong Worldwide Industries is a global leader in water management, and is bent on minimising its reliance on fossil for energy. It has implemented online measurement systems that feed data to its corporate environmental, health and safety system. This empowers it to produce reports, track corrective actions and measure progress towards its overall goal of being carbon neutral.

Next time you sit beneath an Armstrong Worldwide Industries panelled ceiling, spare a thought for how much ecoVaro consumption analytics could contribute to your bottom line (and how it would feel to be lighter on carbon too).

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Implementing Large-Scale Complex Business Change

Sometimes, driving your people to work harder is not enough for your organisation to withstand the pressures laying siege to it. With uncertain economic conditions, unpredictable fresh competition, and looming threats from the environment or even pandemic-grade diseases, empowering your people to not only ‘think’ but also to ‘step’ out of the box is currently the name of the game.

However, such initiatives typically require sweeping changes throughout your entire organisation … and to think even the slightest change is often met with hard resistance.

Whether you’re about to undergo an M&A, relocate due to a major catastrophe, scale down to a skeletal workforce, or implement a brand-new company-wide strategy, our systematic approach to large-scale complex business change can help you make the transition as seamless as possible.

We understand the importance of the human aspect in change management. That is why we’ll focus on making your people appreciate the benefits of having to learn new skills, perform new tasks, employ modern technologies, and go through new processes in order to tone down the resistance level.

Our entire process spans from top to bottom, wherein we’ll start with your sponsors, down to your managers, and then to other stakeholders in making them appreciative of the needed changes and in order to achieve alignment with your organisation’s goals. Our top to bottom approach is also aimed at casting a positive “shadow of the leader” on people down the line, enabling them with an optimistic view despite the gruelling tasks before them.

We invite you to have a look at the steps we take in implementing large-scale complex business change to win over a strong and lasting commitment to it.

Evaluating the Required Change

Large-scale complex business change initiatives can be implemented expeditiously and economically if you’ve clearly defined the scope of the change as well as the forces that shape your organisation. You’ll want to know which areas yield easily and which are hard to change to determine where and how you’re going to focus more of your efforts on.

To arrive at a sound and systematic plan, we first gather as much information as needed and analyse them. We determine whether your departments have the required capabilities and how we can arrive at a clear organisational alignment. That way, we don’t waste time, effort and resources when the moment comes to carry out the plan.

These are some of the diagnostic procedures we perform in evaluating the required change.

  • Change complexity analysis. We’ll assess the contribution of people and task factors to the overall complexity of the change project. This will help us determine how to approach the problem efficiently.
  • Causal analysis. By establishing cause and effect relationships, we can identify root or circular causes. This will allow us to pinpoint problem areas and prevent a repetition of past mistakes.
  • Structural analysis. Any company is propped up by a number of structures: organisational, process, motivational, social, and physical, among others. Understanding the structures that drive, motivate, hamper, connect, and influence your people’s behaviours can provide insights as to how or where structural change can best be executed.
  • Context analysis. We’ll look into market forces as well as political, economic, social, technological, legal, and environmental factors enveloping your business. We’ll also analyse your driving objectives, organisational alignment, and organizational capabilities. By analysing the internal and external environment in which your business currently operates, we can formulate a customised strategic and effective plan of action.

Managing Stakeholders

Change initiatives won’t prosper without total commitment from all stakeholders. Stakeholders refer to people in your organisation who either have interests in the change project or can be affected by it.

We deal with your stakeholders starting from the top because if we can’t gain full commitment from those already in the best position to spur the diverse entities in your company into active cooperation, striving to secure commitment from other areas will be futile.

That is, if you don’t have the full support of your key and principal sponsors, i.e. the people who have the biggest say and have greatest control over resources in your organisation, you can’t hope to sustain the change endeavour, let alone provide the much needed spark to get it started.

Here’s how we carry out our stakeholder management actions.

  • Conduct research to identify all stakeholders: the sponsors, your internal and external partners, the main targets of the change, and all interested parties. That way you can “switch on” implementors of each change action in the proper sequence.
  • Not everyone will offer resistance to your change endeavours. We’ll help you identify those stakeholders and sponsors who are willing to offer support, evaluate the level of support they are willing to give, harness all available supports and utilise them extensively to benefit the change.
  • Gain a deeper understanding as to why certain stakeholders are willing to lend support. In doing so, we can implement the right strategies that will encourage them to continue supporting you.
  • Assemble a leadership team that will champion your change initiatives. We’ll facilitate effective collaboration among its team members, transforming them into a cohesive force designed to carry out plans and motivate everyone else down the line.
  • Upon realisation of the change project, we’ll see to it that all stakeholders get a taste of the carrot at the end of the stick. This will encourage them to continue active cooperation in future change initiatives.

Planning for the Change

Anyone who has experienced having their car stuck in the mud knows that stepping on the accelerator will only get the vehicle trapped even deeper. Without the aid of a towing truck, getting the car out will require careful planning since different combinations of pulling, pushing, lifting, rocking to-and-fro, and stepping on the accelerator may be needed.

Of course, some combinations are just better than others. The same principle holds when effecting change.

Our approach to change management typically varies depending upon the information we obtain from the different analyses performed earlier. For instance, since not all organisations are suitable for a collaborative approach, we will employ either collaborative, consultative, directive, or coercive change management strategies wherever applicable.

A well-planned change will result in a smoother, less costly, and less disruptive transition. Here’s how we’ll help you plan your change initiatives.

  • When put in a predicament similar to the car-in-the-mud, the basic strategy entails identifying the current resisting forces and predicting what other resisting forces may be encountered along the way. After researching and pointing out your organisation’s resistance forces, we’ll lay out the most appropriate facilitation, education, and negotiation techniques.
  • To bring down wastage to the lowest possible levels, we’ll engineer a change delivery plan that involves the most cost-effective sequence of driver, process, technology, organisational, and people alignment.
  • To win and maintain a high level of trust, confidence and commitment from all sponsors and stakeholders, we’ll present a clear road map of the change process as well as landmarks that will prove how far we will have gone. These landmarks will then be brought to each sponsor’s and stakeholder’s attention each time they are arrived at in order to build up assurance and continued commitment.
  • We’ll design measurement tools and schedule reporting deadlines so that you’ll know what to look forward to and when to expect them.

Managing the Change

Your company will hold a better chance of maintaining a sizeable lead over the rest of the pack if you constantly establish a rally point and instil in your stakeholders the drive to rally to that point from the get-go. To make this happen, your company must undertake the unfreezing, transition, and refreezing phases of change skilfully in order to bring all stakeholders into the right mindset.

Our specialists’ systematic and efficient methods for each of these phases are designed to simplify the management of each phase as well as provide a seamless shift from one phase to the next. This is what we’ll do:

  • Set up a change project management office to ensure that everything associated with the change initiative is given the needed attention and resources even while all the other usual processes in your organisation run concurrently.
  • To unfreeze your people and get them started on the road of change, we’ll employ unfreezing techniques wherever they are most appropriate. We’ll resort to different kinds of methods ranging from presenting persuasive evidence justifying the need for change to showing a motivational vision for inspiring your people to embark on the change process.
  • Since it is during the transition phase when your people can find themselves groping in the dark, we’ll offer executive coaches for your senior managers; facilitators to provide guidance during team meetings and other change activities; coaches to educate and inspire them to meet the change with the right attitude; trainers to teach new systems, procedures, and technologies; as well as employ a variety of other techniques in order to make the transition phase as seamless as possible.
  • Although your people should always be ready to undertake the next major change after a previous one, there should be points in between where they can taste the spirit of success, establish a temporary base to rejuvenate, and immediately gain a deeper understanding of the nearby terrain so as to envision the next rally point. We’ll see to it that this vital phase of change is carried out completely.
EU Energy Efficiency Directive & UK?s ESOS

In 2012 the European Union passed its EU Energy Efficiency Directive (EED) into law. This aims to reduce overall energy consumption by 20% by 2020. It placed an obligation on member states to pass back-to-back local legislation by June 2014.

EED Guidelines

The EED provides specific guidelines it expects member nations to address. The list is long and here are a few excerpts from it:

  • Large companies must use energy audits to identify ways to cut their energy consumption
  • Small and medium companies must be incentivised to voluntarily take similar steps
  • Public sector bodies must purchase energy-efficient buildings, products and services
  • Private energy-consumers must be empowered with information to help manage demand
  • Energy distributors / resellers must cut their own consumption by 1.5% annually
  • Legislators are free to substitute green building technology e.g. through better insulation
  • Every year, European governments must audit 3% of the buildings they own

Definition of Energy Audit

An energy-consumption audit is a question of measuring demand throughout a supply grid, with particular attention to individual modules and high demand equipment. While this could be an exercise repeated every four years to satisfy ESOS, it makes more sense to incorporate it into the monthly energy billing cycle.

Because energy use is not consistent but varies according to production cycle, this can produce reams of printouts designed to frustrate busy managers. ecoVaro offers an inexpensive, cloud-based analytic service that effortlessly accepts client data and returns it in the form of high-level graphic summaries.

Potential ESOS Beneficiaries

As many as 9,000 UK companies are obligated to do energy audits because they employ more than 250 employees, have a balance sheet total over ?36.5m or an annual turnover in excess of ?42m. Any smaller enterprise that finds energy a significant input cost, should also consider enlisting Ecovaro to help it to:

  • Obtain a better understanding of the energy side of their business
  • Achieve energy savings and share in a estimated ?3bn bonanza to 2030
  • Reduce carbon emissions to help meet their CRC commitments

More About ecoVaro

We offer web-based energy management software that helps you measure and manage energy costs. This strips data from your meters and generates personalised reports on a dashboard you control. This information helps you accurately zoom in on worthwhile opportunities. With Ecovaro on your side, ESOS truly becomes an Energy Saving OPPORTUNITY Scheme.

Ready to work with Denizon?