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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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.

Field service and customer transparency

These days, a business is as good as it is transparent. Businesses are on unsteady ground because of the ever changing face of social media and a never-seen-before demand for information. With many sources of info on the internet, being credible is a sure way of building trust and loyalty among clients.

Here is an example. Customers will always believe what they see. If they see the work you put into furnishing their favourite products, you have a greater chance of getting their approval. They can invest more in what they see. The clothing merchandise Patagonia did this for their Footprint Chronicles line to show how their jackets are made and worked out fine for them.
Transparency is a must. Nowadays, customers never forget when they feel cheated. It is even harder to ensure transparency because many clients are also experts who scrutinise every detail. So, how can you keep transparency at the forefront?

Have transparent workforce management

Customers always look for new information and want to be in the know. There is nothing worse than not being able find a product manual or an easy way to set up appointments. By giving your clients a self-service option, they can pick the services they want. This leaves more time to get stuff done rather than answering unending service calls from dissatisfied customers.

For instance, you could have a field service customer self-service application that allows customers to look for personalised services, a machine manual, book appointments, or solve any other problem. Customers then get feedback anytime. This one-on-one approach can help customers feel like their questions are being answered. They?ll also not go through the hassle of long hold times to reach an available customer service representative.

Create transparency in field service repair projects

If field technicians have access to field service software, it allows technicians to be more open to customers. This gives them vital information like customer history and the ERP, so that they can explain changes that were made after past enquiries and what is being done in current products. Such information can be a guide for future updates or let the techs suggest products that suit a client’s taste. Unlike always staying offline and out of touch with your client, using field service software can allow entry of allowances and mileage, and also let the customer know the delivery time for their products.

Show customers what they’re paying for

With field service automation, billing will also be transparent. By using the available information about your field service solution, the station can send updated service reports to the customer like mileage, allowances, parts, hours worked, and photos of broken parts from the service. After the customer authenticates the transaction with a signature, the field service agent can generate and sent to the customer an invoice based on the agreed upon services. In case allowances and mileage can be forwarded to the customer, it will be shown on the invoice.
Because you use field service automation, it means that the customer will receive the invoice really fast ? in days rather than weeks ? and transparency will skyrocket because the whole experience of the service will leave a permanent mark in their mind.

Mistaking information for transparency

Being honest with your customer is the one thing. Wasting their time with unnecessary information is another. Here is an experience I had with a small retailer. Tracking information is only useful if it has recent updates and is accurate. If the company want to use real time tracking, let them do so under one condition ? updates should be regular and on time so as not to leave the customer frustrated because they also make plans based on the same information. Late updates shed light on the nature of the service command. Everyone hates cooked-up real time information.

A company must not always have a one to one exchange of information with customers to maintain transparency..

  • Use simple language that all customers can understand
  • Don’t use abbreviations that only employees know
  • Never ever air your failures and flaws to your customers

It is interesting that most of the tools we use to keep in touch with our clients and servicing their requests can also be used to gather data and iron out possible errors to improve products and services. This is a good chance for service providers to evaluate and make necessary amendments.

There are some areas that will need improving while others will not, nevertheless, the client needs to always be informed and know why things are the way they are. Not all details should be told, so filter what you share.

5 ways field service supports customer service

Sales organisations are always in motion, working to deliver the right product to their customers. To keep customers smiling all times is hard and only needs close communication and fulfilling promises that were made to them. This is where the field service delivery team comes in. Field service can either meet this demand or fall short plummeting satisfaction rates.
This is a task that relies on right people using various parts and information to get the job done. No matter what, the customer always expects to get exceptional services whether it be over the phone, chats, in the field, online messaging, over email, or social media.

These five field service points are suitable for any business model and guarantee excellent company-client relations.

Proactive service

A proactive service gives more to the customer. More attention is given to the customer so that the right actions, deliveries and repairs are done. By getting everything right the first time, the customer has less to do ensuring that they are satisfied with the services.
However, the field service technician is flooded with a myriad of unpredictable situations; overheating equipment, stalled machines, and insufficient precaution. But through field management software, they get more data about the customer and type of service or parts expected and they easily ride through any storm and prevent future damage.

Transparency

Nothing frustrates a customer more than a schedule that delays repairs. They easily ditch you for better services elsewhere. By offering the customer a service where they book appointments based on their own availability, we can easily sync this to the technicians and manager?s calendar. This not only saves time but also money from otherwise idle equipment.

On-site and off-site collaboration

Having seamless communication between field and office technicians is vital. Field technicians need to know more about parts, repairs, client maintenance history, and predict what should be changed in the long run. The faster they do this the better.

There should be a system that creates and automates communication between field and office technicians. Let each have the upper hand when providing parts, products or services to the customer.

Flexibility

Information is key to field service agents. They make the first impression since they make the initial contact with clients. Regardless of the resources, the field technician must always be armed with mobile tools they will need to access online resources and be ready for any emergency.

Actionable performance improvements

Customers demand excellent service a company could offer. But as the game constantly shifts, the service management technicians must also come up with plans to stay up to par with competition. All these stems from coming up with KPIs, measuring them and turning them into a workable plan for the future.

A Business Case for Sharing

We blogged about sharing services in a decentralised business context recently, and explained why we think why these should be IT-Based for speedy delivery. This is not to say that all shared services projects worldwide have been resounding successes. This is often down to the lack of a solid business case up front. We decided to lay out the logic behind this process.

Management Overview ? The overview includes a clear definition of why the current situation is unacceptable, the anticipated benefits of sharing, and an implementation plan were it to go ahead. The project should not proceed until the stakeholders have considered and agreed on this.

Alternatives Considered ? The next stage is to get closer to the other options in order to determine whether an alternative might perhaps be preferable. Substitutes for shared services are often doing nothing, improving the current method, and outsourcing the service to a third party.

The Bottom Line in Business ? Sharing services comes at an initial cost of infrastructure changes, and the impact on human capital (the latter deserves its own blog). The following need careful consideration from the financial angle:

Numbers to Work Through

  • Manpower to design and roll the project out in parallel with the existing organisation.
  • Capital for creating facilities at the central point including civil works, furniture and equipment and IT infrastructure.
  • The costs of travel, feeding and accommodation. These can be significant depending on the time that implementation takes.
  • The opportunity loss of diverting key staff – and the cost of temporary replacements – if appointing line staff to the project team.
  • Crystal-clear project metrics including (a) the direct, realisable savings (b) the medium and long-term effects on profit and (c) where to deploy the savings

Risk Management

Shared services projects don’t go equally smoothly, although planning should reduce the risk to manageable levels. Nonetheless it is important to imagine potential snags, decide how to mitigate them and what the cost might be.

We believe in implementing shared services on a pilot basis in the business unit that eventually provides them. We recommend building these out to other branches only when new processes are working smoothly.

Moving On From a Decision

We recommend you revisit your management overview, the logic behind it, the assumptions you made, and the costs and benefits you envisage before deciding to go ahead

The final step in proving a business case is doable should be fleshing out your roadmap into a detailed operations plan with dependencies on a spreadsheet.

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