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

Check our similar posts

2015 ESOS Guidelines Chapter 3 ? The ESOS Assessment

ESOS operates in tandem with the ISO 50001 (Energy Management) system that encourages continual improvement in the efficient use of energy. Any UK enterprise qualifying for ESOS that has current ISO 50001 certification on the compliance date by an approved body (and that covers the entire UK corporate group) may present this as evidence of having completed its ESOS assessment. It does however still require board-level certification, following which it must notify the Environment Agency accordingly.

The Alternate ESOS Route

In the absence of an ISO 50001 energy management certificate addressing comprehensive energy use, a qualifying UK enterprise must:

  1. Measure Total Energy Consumption in either kWh or energy spend in pounds sterling, and across the entire operation including buildings, industrial processes and transport.
  2. Identify Areas of Significant Energy Consumption that account for at least 90% of the total. The balance falls into a de minimis group that is officially too trivial to merit consideration.
  3. Consider Available Routes to Compliance. These could include ISO 500001 part-certification, display energy certificates, green deal assessments, ESOS compliant energy audits, self-audits and independent assessments
  4. Do an Internal Review to make sure that you have covered every area of significant consumption. This is an important strategic step to avoid the possibility of failing to comply completely.
  5. Appoint an Approved Lead Assessor who may be internal or external to your enterprise, but must have ESOS approval. This person confirms you have met all ESOS requirements (unless you have no de minimis exceptions).
  6. Obtain Internal Certification by one of more board-level directors. They must certify they are satisfied with the veracity of the reports. They must also confirm that the enterprise is compliant with the scheme.
  7. Notify the Environment Agency of Compliance within the deadline using the online notification system at snapsurveys.com as soon as the enterprise believes is fully compliant.
  8. Assemble your ESOS Evidential Pack and back it up in a safe place. Remember, it is your responsibility to provide proof of the above. Unearthing evidence a year later it not something to look forward to.

The ESOS assessment process is largely self-regulatory, although there are checks and balances in place including lead assessor and board-level certifications. As you work through what may seem to be a nuisance remember the primary objectives. These are saving money and reducing carbon emissions. Contact Ecovaro if we can assist in any way.

How Accenture Keeps Rolling Out Sustainability

Multinational management-consulting and technology-services company Accenture has a good eye for sniffing out new business, with 305,000 employees advancing its interests in more than 200 cities in 56 countries evidence. Last year, it netted US$30 billion profit that is a tidy sum of money in anybody?s books.

Accenture also practices what it preaches. This is maximum business efficiency within moral standards. It tracks its carbon emissions from its offices around the world. Being a technology services company it is unsurprising that it automated the process. Being management consultants it can drill down to finest detail in its search for continuous improvement.

As a forward-thinking company Accenture is committed to transplanting its business skills into other organizations, in order to drive higher performance and sustain greater profits in the long term. It works with clients across borders and industries to integrate sustainability into their business models, and find effective ways to lighten carbon footprints.

The City of Seattle in Washington is a case in point. Following a proud history of nature and energy conservation, it engaged Accenture in 2013 to help it reduce downtown power consumption by 25%. Other project members were Microsoft supplying software, the local power utility for technical advice, and a non-profit to set up a smart building program. The initiative uses cloud services to process the big data generated by a host of building management services, plus a multitude of sensors, controls and meters.

The project is vital for the City. It wants to continue expanding but needs to avoid another power plant polluting its skyline. At the time of writing, the pilot sites had proved successful and the program was rolling out. Seattle?s next challenge is to acquire 15% of its energy from renewable sources by 2020.

The smart building solutions Seattle trialled in five downtown buildings, had a further welcome spinoff; by reducing operating times, facility managers can look forward to extended equipment life and fewer maintenance downtimes. The green building philosophy is alive and well in the City of Seattle, driven both by necessity and vision.

It is a no longer as question of if – but when – other urban communities follow suit. EcoVaro believes it is time long due for individual companies to start enjoying lower energy costs plus the prospect of profitably trading carbon credits. The process begins with measuring what you have and identifying cost-effective savings.

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK
Field Service Organisations should use Digital Forms

For many Organisations, making use of paper based forms, is a common practice and method for collecting data and recording transactions. Whether it be for producing Quotations, Invoices or even getting sign off on completed jobs.

Paper based forms and documents have been the main stay of office communication and productivity for over 200 years. Paper-based forms are used to create anything from Invoices, Receipts, Purchase Orders, Contracts to the humble internal memo!

Paper-based forms radically improved productivity, efficiency and compliance by enabling people to create paper based instructions and enabling others to add additional information as required.

Over the past 3 decades or so, modern business environments have gradually been evolving towards the concept of the Paperless Office, resulting in the humble Paper based document migrating to a Digital Counterpart. The ease of availability of various Word Processing and Spreadsheet software products and cheap and easy data storage capacity have resulted in the Proliferation of thousands if not millions of files and documents being stored somewhere on the Company’s IT infrastructure.

People often create Digital Templates of forms that may be printed off and supplied to staff to complete using Pen and Paper or electronically. The data collation and reporting is often process

Often when conducting Operational Reviews, it is commonly found that the processing and analysing paper based forms is the least productive, efficient and profitable areas of business, although it is often vitally important.

Benefits of using digital forms for data collection

The ability to collect and analyse data effectively is increasingly important to businesses. Companies gather, examine, process and build reports on large volumes of data. Traditionally, they have deployed mail surveys, telephone interviews, door-to-door interviews as methods to collect information. With the ongoing digitisation, these procedures have become old fashioned.The digital transformation is changing many business operations at a high speed and a great deal of processes that were executed manually are now accomplished using digital methods.

Technology has had a major impact on how to approach data research and has provided researchers new tools that have transformed and improved data collection and analysis. The pace of change requires companies to be able to react quickly and adapt themselves to changing demands from customers and market conditions.

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK

Ready to work with Denizon?

Contact Us Today