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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Technology and process improvement

Tightening organisational flow to improve productivity and minimise costs is a growing concern for many businesses post the Global Financial Crisis. Businesses can no longer afford to waste time and personnel on inefficient processes. Organisations using either Six Sigma or Lean techniques better manage their existing resources to maximise product out-put. Both of these techniques involve considerable evaluation of current processes.

What is Six Sigma?

Six Sigma is an organisational management strategy that evaluates processes for variation. In the Six Sigma model, variation equates waste. Eliminating variation for customer fulfilment allows a business to better serve the end-user. In this thought model, the only way to streamline processes is to use statistical data. Each part of a process must be carefully recorded and analysed for variation and potential improvements. The heart of the strategy embodied by Six Sigma is mathematical. Every process is subject to mathematical analysis and this allows for the most effective problem solving.

What is a Lean Model?

Lean businesses do not rely on mathematical models for improvement. Instead, the focus is on reducing steps in the customer delivery cycle, which do not add value to the final deliverable. For example, maintaining excess inventory or dealing with shortages would both be examples of waste behaviour. Businesses that operate using Lean strategies have strong cash flow cycles. One of the best and most famous examples of Lean in action is the Toyota Production System (TPS). In this system, not only is inventory minimised, but physical movement for employees also remains sharply controlled. Employees are able to reach everything needed to accomplish their tasks, without leaving the immediate area. By reducing the amount of movement needed to work, companies also remove wasted employee time.

Industry Applications for Lean and Six Sigma

Lean businesses reduce the number of steps between order and delivery. The less inventory on hand, the less it costs a business to operate. In industries where it is possible to create to order, Lean thinking offers significant advantages. Lean is best utilised in mature businesses. New companies, operating on a youthful model, may not be able to identify wasteful processes. Six Sigma has shown its value across industries through several evolution’s. Its focus on quality of process makes it a good choice for even brand new businesses. The best use is the combination of the two strategies. With the Lean focus on speed and the Six Sigma focus on quality combined, the two organisational processes create synergy. By itself, Lean does not help create stable, repeating success. Six Sigma does not help increase speed and reduce non value-added behaviours. Combined, these two strategies offer incredible value to every business in cost savings.

Using Technology to Implement Lean Six Sigma

Automation processes represent an opportunity for businesses to implement a combination of both Lean and Six Sigma strategies. Any technology that replaces the need for direct human oversight reduces costs and increases productivity. A few examples of potentially cost saving IT solutions include document scanning, the Internet, and automated workflow systems.

  • Document Scanning – Reducing dependency on paper copies follows both Lean and Six Sigma strategies. It is a Lean addition in that it allows employees to access documents instantly from any physical location. It is Six Sigma compliant in that it allows a reduction on process variation, since there is no bottleneck on the flow of information.
  • The Internet – The automation potential offered by the Internet is limitless. Now, businesses can enter orders, manage logistics and perform customer service activities from anywhere, through a hosted portal. With instant access to corporate processes from anywhere, businesses can manage workflow globally, allowing them to realise cost savings from decentralisation.
  • Automated Work Systems – One of the identified areas of waste in any business is processing time. The faster orders are processed and delivered, the greater the profits for the company and the less the expense per order. When orders sit waiting for attention, they represent lost productivity and waste. Automated work systems monitor workflow and alert users when an item sits longer than normal. These systems can also reroute work to an available employee when the original worker is tied up.

Each of these IT solutions provides a method for businesses to either reduce the number of steps in a process or improve the quality of the process for improved customer service.

Identifying Areas for Lean Six Sigma Implementation

Knowing that improved processes result in improved profits, identifying areas for improvement is the next step. There are several techniques for creating tighter processes with less waste and higher quality. Value Stream Mapping helps business owners and managers identify areas of waste by providing a visual representation of the total process stream. Instead of improving single areas for minimal increases in productivity, VSM shows the entire business structure and flow, allowing management to target each area of slow down for maximum improvement in all areas.

Seeing the areas of waste helps management better determine how processes should work to best obtain the desired outcomes. Adding in automated processes helps with improved process management, when put in place with a complete understanding of current systems and their weaknesses. Start with mapping and gain a bird’s-eye view of the situation, in order to make the changes needed for improvement.

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4 Reasons Why You Might be Missing Out on Energy Savings…

?well your company actually, although for many small-to-medium businesses it boils down to the same thing. Governments usually lag behind in terms of innovation but are beating us hands-down when it comes to going green. I have heard that private sector energy savings average less than 1% per year and I for one would not be surprised if that were true. So what is causing this rot, when we started out so enthusiastically? Here are four possibilities for you to mull over.

  1. Your Team is Unevenly Yoked ? A pair of mismatched horses cannot pull a wagon in a straight line any more successfully than a business team can achieve its goals, if there is no agreement on priorities. While your sales team may be all for scoring green points against your competition, your accountant has a budget to balance and your operations department just wants to get on with the job.
  1. Energy?s not in Focus ? The above may in part be due to production goals you set your department heads. Energy is not nearly as greedy as raw materials and human capital. If you tell them to cut 5%, where do you think they are going to look first? You need to put energy savings up there, and agree specific targets as you do with other primary goals.
  1. Your Equipment Could be Over-Spec ? It is a very human thing to put more food on our plates and buy faster cars than we need. Only a few generations ago our ancestors lived through feast and famine, and the shadow of this still influences our thinking. Next time you buy equipment sit around the table and agree the decision criteria together. Then stick to them and repel all attempts at up-selling.
  1. You Are Delegating Too Much ? Delegation is part of company culture, or if you prefer the collective way of doing things. If you delegate something completely it is akin to saying I do not care much about this, make it happen. Energy saving is a financial and moral imperative. The fact the oil price is down does not mean there is no place for sustainability on your desk (and the price is likely to be up again soon).

Governments succeed in saving energy (whereas businesses often do not) because governments have a crowd of stakeholders beating down the door and demanding progress. As business owners we are more likely to do the same when the pressure is upon us, and that pressure surely has to come from us.

Benefits of Energy Savings Opportunity Scheme (ESOS)

More than just building energy, improving skills and undertaking audits, Energy Savings Opportunity Scheme works beyond. ESOS adheres to policy coherence, provides information to raise awareness, facilitates energy efficiency market and encourages adoption of appropriate energy efficiency measures.

Generally, ESOS is great for energy professionals and businesses. And in the current situation of UK?s energy industry, this new scheme is a substantial help. The key is to know the benefits that ESOS provides, understand how it can affect you, learn how to maximise its potential and make a big difference. Here?s to explore the highlights of ESOS.

Who benefits from ESOS?

Energy Savings Opportunity Scheme covers non-SME enterprises which includes UK businesses having more than 250 employees; even those with employees fewer than 250 but have annual turnover of more than ?50m and balance sheet exceeding ?43m; or those professionals that belong to a large enterprise. This is in accordance with what Article 8 of the EU Derivative provides.

What are the benefits of ESOS?

ESOS provides opportunities to enhance an organisation’s energy efficiency strategy, of which the benefits include:

Economic Growth and Competitiveness

The implementation of energy efficient measures increases local employment in the labour markets. Consequently, this taps the labour potential and drives economic growth.? In a lower carbon economy, businesses need to develop green projects to maintain economic competitiveness as well. ESOS is strategic approach initiated by the UK government to push technological innovation and energy investments.

Cost Savings and Emission Reductions

ESOS is flexible in such a way that it combines energy policies and innovations tailored to every organisation’s need. The energy efficiency measures taken, resulting from the scheme, quickly cuts down both carbon emissions and energy bills at cheapest possible ways.

Managing Energy Demand

ESOS provides energy security to UK by reducing the energy consumption of enterprises. With this, the economy would be more efficient and less exposed to international energy market volatility. Also, this will lead to more savings from less future investment in energy infrastructure.

Getting your Management Performance Noticed

If you are an energy professional, you will benefit from ESOS by exploiting it ?to boost your charisma towards the company directors. You can show them how the scheme works and how it can save your company substantial costs. Managing energy with ESOS can help an organisation grow. Nevertheless, you are the key person designated to get the project done and achieve success.

How can ESOS make a difference?

More than anything else, ESOS can make a huge change. True to its name, it provides large enterprises the opportunity to manage energy wisely, reduce overhead costs and promote responsible corporate energy consumption.

The International Energy Agency said that investing in energy efficiency leads to growth, additional jobs, competent budgets on public spending and enhanced industry productivity. If you are an energy and environment professional or a non-SME business entity, you hold the impulse to act. Aside from all those excellent business benefits that you get to enjoy, you will be able to contribute a portion towards achieving UK?s national carbon target of 80% in CO2 by 2050.

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