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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Succeed at Transformation

Despite the pomp and fanfare associated with launching corporate transformation programs, in reality very few of them succeed. According to a recent report by McKinsey the success rate is pegged below 40%. In addition, the same research indicates that defensive transformations – those undertaken as part of crisis management – have lower chances of success than progressive ones – those launched to streamline operations and foster growth. However, adopting certain strategies, like setting clear and high goals, and maintaining energy and engagement throughout the implementation phase, can really boost the project’s success rate. A key aspect of business transformation is IT transformation. This can be attributed to the fact that significant business change is either driven or influenced by technological change.

So what is IT Transformation?

IT transformation is basically a holistic reorganisation of the existing technological infrastructure that supports the company’s mission critical functions. In essence, IT transformation is not all about effecting change for the sake of change but involves systematic steps that align IT systems to business functions. To appreciate this approach, it is important to explore current trends in the business world where human resource, finance and IT transformations are being carried out in unison. This is being done to develop strong corporate centres that are leaner, agile and more productive that enhance greater synergies across all business functions.

IT transformation inevitably results in major changes of the information system’s technology, involving both hardware and software components of the system, the architecture of the system, the manner in which data is structured or accessed, IT control and command governance, and the components supporting the system. From this scope of works it is evident that IT transformation is a huge project that requires proper planning and implementation in order to succeed.

Tips to Improve Success in IT transformations Projects

1. Focus on Benefits not Functionality

The project plan should be more focused on benefits that can be accrued if the system is implemented successfully rather than system functionality. The benefits should be in line with business goals, for instance cost reduction and value addition. The emphasis should be on the envisaged benefits which are defined and outlined during the project authorisation. The business benefits outlined should be clear, feasible, compelling and quantifiable. Measures should be put in place to ensure that the benefits are clearly linked to the new system functionality.

2. Adopt a Multiple Release Approach

Typically most IT projects are planned with focus on a big launch date set in years to come. This approach is highly favoured because it simplifies stakeholder expectation management and avoids the complexity associated with multiple incremental releases. However, this approach misses the benefit of getting early critical feedback on functioning of the system. In addition, the long lead times often result in changes in project scope and loss of critical team members and stakeholders. IT transformation projects should be planned to deliver discrete portions of functionality in several releases. The benefit of multiple release approach is that it reduces project risks and most importantly allows earlier lessons learnt to be incorporated in future releases.

3. Capacity of the Organisation to confront Change

As pointed out, IT transformations result in significant changes in business operations and functions. Hence it is important that all business stakeholders should be reading from the same script in regards to changes expected. In addition, key stakeholders should be involved in crucial project stages and their feedback incorporated to ensure that the system is not only functional but business focused.

ESOS What is the Truth?

When the UK administration introduced its ESOS Energy Savings Opportunity Scheme reactions from business people followed a familiar theme.

  • Do nothing it will go away
  • The next Westminster will drop this
  • Another stealth tax. I don’t have time for this
  • Give the problem to admin and tell them to fix it

ecovaro decided to share three facts with you. These are

(1) ESOS is not a government money spinner

(2) all major political parties support it, and

(3) it is a cost-effective way to put money back in your pocket while feeling better about what business pumps into the environment.

Four More ESOS Facts

1. You Cannot Give the Problem to Admin ? Energy is technical. The lead belongs with your operations staff because they understand how your systems work. Some things are best outsourced though. ecovaro is here to help.

2. ESOS is Not Going to Go Away ? A company inside the regulation net must submit its first report by 6 December 2015. Non-compliance risks the following penalties:

  • ?5,000 for not maintaining adequate records
  • ?50,000 for not completing the assessment
  • ?50,000 for making a false or misleading statement

3. The Employee Count is the Annual Average – The employment criteria (unlike balance sheet and turnover) is the monthly average of full and part-time employees taken across the full financial year. The fact you have <250 employees in December 2015 when the first report is due does not necessarily let you off the hook.

4. The 6 December 2014 Report is No Big Deal ? When you think about it the administration is hardly likely to spend years wading through 9,000 detailed company energy plans. It has no authority to comment in any case. All that is required is for a senior director to confirm reading the document, and a lead assessor to agree it complies with the law.

Does this mean that ESOS is a damp squib? We do not think so, although some firms may take the low road. ecovaro believes the financial benefits will carry the process forward, and that the imperative to make the world a better place will do the rest.

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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