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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The word ?Kanban? comes from a Japanese word meaning ?billboard? or ?signboard?. Before going into more detail how this works let’s first examine how Japanese beliefs of collaboration, communication, courage, focus on value, respect for people and a holistic approach to change fit into the picture.

The Four Spokes Leading to the Kanban Hub

  1. Visualise the Workflow ?You cannot improve what you cannot see. The first step involves team members reducing a project to individual stages and posting these on a noticeboard.
  2. Create Batches ? These stages are further reduced to individual tasks or batches that are achievable within a working day or shift. More is achievable when we do not have to pick up where we left off the previous day.
  3. Choose a Leader the Team Respects – Without leadership, a group of people produces chaotic results. To replace this with significant value they need a leader, and especially a leader they can willingly follow.
  4. Learn and Improve Constantly ? Kaizen or continuous improvement underpins the Japanese business model, and respects that achievement is a step along the road, and not fulfilment.

The Kanban Method in Practice

Every Kanban project begins with an existing process the participants accept will benefit from continuous change. These adjustments should be incremental, not radical step-changes to avoid disrupting the stakeholders and the process. The focus is on where the greatest benefits are possible.

Anybody in the team is free to pull any batch from the queue and work on it in the spirit of collaboration and cooperation. That they do so, should not make any waves in a culture of respect for people and a holistic approach to working together. All it needs is the courage to step out of line and dream what is possible.

The Kanban Project Method ? Conclusions and Thoughts

Every engine needs some sort of fuel to make it go. The Kanban project management method needs collaboration, communication, courage, focus on value, respect for people and a holistic approach to work. This runs counter to traditional western hierarchies and probably limits its usefulness in the West.

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Energy Audit – clearly clear?

An energy audit is an examination of an energy system to ensure that energy is being used efficiently. It is the inspection, survey and analysis of energy flows for energy conservation in a building. Energy audits can be conducted by building managers who examine the energy account of an energy system, checks the way energy is used in its various components, checks for areas of inefficiency or where less energy can be used, and identifies the means for improvement.

An energy audit is often used to identify cost effective ways to improve the comfort and efficiency of buildings. In addition, homes/ enterprises may qualify for energy efficiency grants from central government. Energy audits seek to prioritise the energy uses from the greatest to least cost effective opportunities for energy savings.

An energy audit is an effective energy management tool. By identifying and implementing improvements as identified, savings can be achieved not only on energy bills, but also equipment will be able to attain a longer life under efficient operation. All these mean actual dollar savings.

An energy audit has to be conducted by a competent person with adequate technical knowledge on building services installations, after which he/she comes up with a report recommending plans on the Energy Management Opportunities (EMO) for energy saving.

An energy audit culminates to a written report. This could show energy use for a given time period (for example a year) and the impact of any suggested improvements per year. Energy audit reports are then used to identify cost effective ways to improve the comfort and efficiency of buildings. The energy audit report therefore gives management an understanding of the energy consumption scenario and energy saving plans formulation.
Energy audit reports should always translate into action. No matter how well articulated, the energy management objectives are afterall, an energy audit (EMOs), all the effort will be futile if no action is taken. The link between the audit and action is the audit report. It is therefore important for the audit reports to be understandable for all the target audiences/ readers, all of whom may have diverse needs, hence the reason why they should be clear, concise and comprehensible.

What are the do?s and don’ts when writing energy audit reports?

Avoid technical jargon as much as possible; present information graphically; use different graphics such as pie charts, data tables. Schematics of equipment layouts and digital photos tend to make EMO reports less dry. Some of the energy audit software?s come in handy in the generation of such graphs and charts.
The climax of it all is the recommendations, which should be made very fascinating.

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What Energy Management Software did for CDC

Chrome Deposit Corporation ? that’s CDC for short ? reconditions giant rollers used to finish steel and aluminium sheets in Portage, Indiana by applying grinding, texturing and plating methods. While management was initially surprised when the University of Delaware singled their plant out for energy assessment, this took them on a journey to bring energy consumption down despite being in an expansion phase.

Metal finishing and refinishing is an energy-intensive business where machines mainly do the work while workforces as small as 50 individuals tend them. Environmental impacts also need countering within a challenging environment of burgeoning natural gas and electricity prices.

The Consultant’s Recommendations

The University of Delaware was fortunate that Chrome Deposit Corporation had consistently measured its energy consumption since inception in 1986. This enabled it to pinpoint six strategies as having potential for technological and process improvements.

  • Insulate condensate tanks and pipes
  • Analyse flue gas air-fuel ratios
  • Lower compressed air pressures
  • Install stack dampers on boilers
  • Replace belts with pulleys and cogs
  • Fit covers on plant exhaust fans

CDC implemented only four of the six recommendations. This was because the boiler manufacturer did not recommend stack dampers, and the company was unable to afford certain process automation and controls.

Natural Gas Savings

The project team began by analysing stack gases from boilers used to heat chrome tanks and evaporate wastewater. They found the boilers were burning rich and that several joints in gas lines were leaking. Correcting these issues achieved an instant gas saving of 12% despite increased production.

Reduced Water Consumption

The team established that city water was used to cool the rectifiers. It reduced this by an astonishing 85% by implementing a closed-loop system and adding two chillers. This also helped the water company spend less on chemicals, and energy to drive pumps, purifiers and fans.

Summary of Benefits

Electricity consumption reduced by 18% in real terms, and natural gas by 35%. When these two savings are merged they represent an overall 25% energy saving. These benefits were implemented across the company?s six other plants, resulting in benefits CDC management never dreamed of when the University of Delaware approached them.

ecoVaro offers a similar data analytics service that is available online worldwide. We have helped other companies slash their energy bills with similarly exciting results. We?ll be delighted to share ideas that only data analytics can reveal.

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