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.

Vendor Selection

When shopping for an IT solution for your enterprise, there are two things you should scrutinise: the product (or service) itself and its vendor. Many times, companies overlook the importance of the latter, giving the reason that “it’s only the product we need”.

Wrong.

What about after-sales technical support and training? Ok, so you have an in-house team with the required competency for that IT solution in question… not that I believe it’s reasonable basis to pass up on the expertise that the vendor can provide. How about upgrades, patches, and documentation?

Still unperturbed? Here’s one factor that you may not have started to consider – What happens to your product if the vendor goes bankrupt or gets swallowed by a merger and acquisition? Surely, you no longer believe this is far from possible, do you?

But how are you supposed to know the financial stability of each vendor or whether it is an acquisition target? Well, you can either conduct your own research or you can leave that up to us. Part of our job includes not only establishing linkages in the industry but also being in-the-know on such relevant information.

Evaluation of Business Needs

You can’t separate vendor selection from the process of choosing the desired IT tool. That’s why our vendor selection services starts by defining exactly what your business needs are.

Once we’ve pinned down your needs, we can then narrow down the list of possible IT solutions. Only then can we proceed with the main vendor selection process.

Have you ever been caught in a situation wherein you thought you knew what you wanted, only to end up realising it’s not what you were looking for after all? We’re here to make sure you don’t get caught in that kind of situation when choosing an enterprise-class IT solution.

With the TCO (total cost of ownership) of such solutions typically running up to hundreds of thousands of euros, you can’t afford to arrive at what you really want by way of trial and error.

These are the things you stand to benefit the moment we start working with you:

  • Thorough assessment of your IT needs. We’ll consult the people in your organisation who’ll be affected the most in order to obtain a clear picture of what your specific needs really are. Most IT solution purchases are made with very little consultation that, after installation, many of the end users don’t benefit at all.
  • Minimal interruption during assessment. As with all our other services, we see to it that the interruptions we make are absolutely necessary. So the moment we start with our work, you can still continue with yours.
  • Insightful suggestions of the required IT solution. You still know your business better. So even after we’ve gone through the assessment and given our recommendations, the decision as to what IT tool should be pursued will still be up to you. The difference now is, you’ll be making a decision based on expertly gathered information put forward in an insightful proposal.

Request and Evaluation of Vendor Proposals

With so many IT solutions companies mushrooming, it is becoming more difficult to keep track of them, their specialities, strengths, and weaknesses.

Companies selling best-of-breed products may be relatively easy to spot. But there are also other attributes that are equally important but not as well publicised. For instance, which companies offer better quality management philosophies? Which companies have strategic visions running parallel to yours? Which of them possess implementation capabilities that can cater to your rapidly growing IT requirements?

Vendors who answer positively to these queries need to be given the appropriate importance in the selection process. We see to it that these and other relevant attributes are factored into our scorecards and evaluation processes.

These are the things you can look forward to when you grant us the opportunity to serve you.

  • Experience is a vital item in our vendor selection criteria. Our vast knowledge of the reliable players in the industry will lead you to experienced vendors who can hit the ground running from day one and continue with the same vigour onward.
  • We can help you draw positive response for each of your Request For Proposals (RFPs) or Request For Information (RFIs). Did you expect these vendors to be enthusiastic in sending out proposals each time you asked them to? Think again. You’ll have to persuade them first of your sincerity to become a potential customer. With our help, your RFPs will make preferred vendors see “opportunity” written all over.
  • No need to go “Eany, meeny, miny, moe”. Deciding which vendors should move up in the selection process can take up a lot of time if you don’t know which criterion should be given more weight. Our scorecards are designed to collect the most relevant information and to generate results that will help you decide on these matters at a glance.

Interview, Negotiation, and Monitoring

As soon as you start getting positive response to your Request For Proposals, the interview process should be next. It’s at this point that vendors can present and highlight their strengths while we try to glean as much information of their true capabilities as well as their dedication to the project.

Some companies can provide proof-of-concepts and we may require them as part of the interview process. This will not only give us a better idea as with regards to their product’s capabilities, but also to their level of expertise on the solution in question.

  • We’ll help you set up the interview process and organise the evaluation committee. Members of the committee will typically include representatives from each department that will be affected by the new technology, which we would have already identified during our Evaluation of Business Needs.
  • Since our scorecards are designed to expedite the filtering and selection process, you may eventually be able to choose the finalists yourself. However, in the event that two or more vendors turn out evenly matched, we’ll help you identify the better company.
  • We’re very familiar with the price ranges of various IT solutions, including the effects on price of certain variables. As such, we can tell you whether a product’s price tag is justified or not.
  • Our exceptional familiarity on both the IT industry and the entire negotiation processes itself will give you the edge when it’s time for us to haggle for the best bang for the buck.
  • After the contract is awarded, we’ll even be on hand to monitor whether deliverables are handed over and milestones are achieved as promised.
Saving Energy Step 2 ? More Practical Ideas

In my previous blog, we wrote about implementing a management system. This boils down to sharing a common vision up and down and across the organisation, measuring progress, and pinning accountability on individuals. This time, we would like to talk about simple things that organisations can do to shrink their carbon footprints. But first let’s talk about the things that hold us back.

When we take on new clients we sometimes find that they are baffled by what I call energy industry-speak. We blame this partly on government. We understand they need clear definitions in their regulations. It’s just a pity they don’t use ordinary English when they put their ideas across in public forums.

Consultants sometimes seem to take advantage of these terms, when they roll words like audit, assessment, diagnostic, examination, survey and review across their pages. Dare we suggest they are trying to confuse with jargon? We created ecoVaro to demystify the energy business. Our goal is to convert data into formats business people understand. As promised, here are five easy things your staff could do without even going off on training.

  1. Right-size equipment? outsource peak production in busy periods, rather than wasting energy on a system that is running at half capacity mostly.
  2. Re-Install equipment to OEM specifications ? individual pieces of equipment need accurate interfacing with larger systems, to ensure that every ounce of energy delivers on its promise.
  3. Maintain to specification ? make sure machine tools are within limits, and that equipment is well-lubricated, optimally adjusted and running smoothly.
  4. Adjust HVAC to demand ? Engineers design heating and ventilation systems to cope with maximum requirements, and not all are set up to adapt to quieter periods. Try turning off a few units and see what happens.
  5. Recover Heat ? Heat around machines is energy wasted. Find creative ways to recycle it. If you can’t, then insulate the equipment from the rest of the work space, and spend less money cooling the place down.

Well that wasn’t rocket science, was it? There are many more things that we can do to streamline energy use, and coax our profits up. This is as true in a factory as in the office and at home. The power we use is largely non-renewable. Small savings help, and banknotes pile up quickly.

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