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
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Align IT Investments With Organization Goals

While some organisation leaders loathe spending on IT, a growing number are already convinced of the necessity of investing in it. Unfortunately, a substantial fraction of those convinced to pursue IT investments are misguided as to which initiatives are really contributory to reaching their organisation’s goals.

In the end, many of their purchases either end up underutilised or become white elephants altogether. There are also those difficult to spot – IT purchases that do become integrated into daily operations but have little effect on the organisation’s growth, positioning, profitability, or efficiency.

If a purchase is to cost your company a fortune, then its positive impact on established company objectives should reflect accordingly. But how would you know it would? You can’t hope to foresee all its benefits especially if the IT solution is still quite new to you.

Our job is not only to identify the strengths of an IT system but also to determine whether these strengths are at all useful to your organisation’s thrusts.

Basically, here’s what we’ll do:

  • Conduct a rigorous analysis of your organisation to determine the specific and overall impact of certain IT solutions. We’ll be looking for areas where the effects of IT can result in the most rapid reduction of costs and, at the same time, drive the organisation in the direction of its established goals.
  • Propose cohesive best-of-breed solutions in line with the results of our analysis. Our familiarity with the IT landscape and our extensive selection of contacts in the industry will allow us to conduct insightful picks from a vast field of choices.
  • Establish best practices to make sure IT investments are optimally utilised.
  • Perform periodic reviews to ensure practices and processes are still in line with the established goals.

Find out how we can increase your efficiency even more:

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Transformation to a process based organisation

Today’s global marketplace rewards nimble organisations that learn and reinvent themselves faster than their competition. Employees at all levels of these organisations see themselves as members of teams responsible for specific business processes, with performance measures tied to the success of the enterprise. As team members, they are “owners” of the process (or processes) to which they are assigned. They are responsible for both the day to day functioning of their process(s), and also for continuously seeking sustainable process improvements.

Transforming a traditionally designed “top down control” enterprise to a process-based organisation built around empowered teams actively engaged in business process re-engineering (BPR) has proven more difficult than many corporate leaders have expected. Poorly planned transformation efforts have resulted in both serious impacts to the bottom line, and even more serious damage to the organisation’s fabric of trust and confidence in leadership.

Tomislav Hernaus, in a publication titled “Generic Process Transformation Model: Transition to Process-based Organisation” has presented an overview of existing approaches to organisational transformation. From the sources reviewed, Heraus has synthesised a set of steps that collectively represent a framework for planning a successful organisational change effort. Key elements identified by Hernaus include:

Strategic Analysis:

The essential first step in any transformation effort must be development of a clear and practical vision of a future organisation that will be able to profitably compete under anticipated market conditions. That vision must be expected to flex and adjust as understanding of future market conditions change, but it must always be stated in terms that all organisational members can understand.

Identifying Core Business Processes:

With the strategic vision for the organisation in mind, the next step is to define the core business processes necessary for the future organisation to function. These processes may exist across the legacy organisation’s organisational structures.

Designing around Core Processes:

The next step is development of a schematic representation of the “end state” company, organised around the Core Business Processes defined in the previous step.

Transitional Organisational Forms/ Developing Support Systems:

In his transformation model, Hernaus recognises that information management systems designed for the legacy organisation may not be able to meet the needs of the process management teams in the new organisation. Interim management structures (that can function with currently available IT system outputs) may be required to allow IT professionals time to redesign the organisation’s information management system to be flexible enough to meet changing team needs.

Creating Awareness, Understanding, and Acceptance of the Process-based Organisation:

Starting immediately after the completion of the Strategic Analysis process described above, management must devote sufficient resources to assure that all organisation members, especially key managers, have a full understanding of how a process-based organisation functions. In addition, data based process management skills need to be provided to future process team members. It is not enough to schedule communication and training activities, and check them off the list as they are completed. It is critical that management set behavioural criteria for communication and training efforts that allow objective evaluation of the results of these efforts. Management must commit to continuing essential communication and training efforts until success criteria are achieved. During this effort, it may be determined that some members of the organisation are unlikely to ever accept the new roles they will be required to assume in a process-based organization. Replacement of these individuals should be seen as both an organisational necessity and a kindness to the employees affected.

Implementation of Process Teams:

After the completion of required training AND the completion of required IT system changes, process teams can be formally rolled out in a planned sequence. Providing new teams with part time support by qualified facilitators during the firsts weeks after start-up can pay valuable long term dividends.

Team Skill Development and Continuous Process Improvement:

Providing resources for on-going skill development and for providing timely and meaningful recognition of process team successes are two keys for success in a process-based organisation. Qualified individuals with responsibility for providing training and recognition must be clearly identified and provided with sufficient budgetary resources.

The Hernaus model for transformation to a process based organisation is both well thought out and clear. His paper provides an ample resource of references for further study.

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Sources of Carbon Emissions

Exchange of carbon dioxide among the atmosphere, land surface and oceans is performed by humans, animals, plants and even microorganisms. With this, they are the ones responsible for both producing and absorbing carbon in the environment. Nature?s cycle of CO2 emission and removal was once balanced, however, the Industrial Revolution began and the carbon cycle started to go wrong. The fact is that human activities substantially contributed to the addition of CO2 in the atmosphere.

According to statistics gathered by the Department of Energy and Climate Change, carbon dioxide comprises 82% of UK?s greenhouse gas emissions in 2012. This makes carbon dioxide the main greenhouse gas contributing to the pollution and subsequent climate change in UK.

Types of Carbon Emissions

There are two types of carbon emissions ? direct and indirect. It is easier to measure the direct emissions of carbon dioxide, which includes the electricity and gas people use in their homes, the petrol burned in cars, distance of flights taken and other carbon emissions people are personally responsible for. Various tools are already available to measure direct emissions each day.

Indirect emissions, on the other hand, include the processes involved in manufacturing food and products and transporting them to users? doors. It is a bit difficult to accurately measure the amount of indirect emission.

Sources of Carbon Emissions

The sources of carbon emissions refer to the sectors of end-users that directly emit them. They include the energy, transport, business, residential, agriculture, waste management, industrial processes and public sectors. Let’s learn how these sources contribute carbon emissions to the environment.

Energy Supply

The power stations that burn coal, oil or gas to generate electricity hold the largest portion of the total carbon emissions. The carbon dioxide is emitted from boilers at the bottom of the chimney. The electricity, produced from the fossil fuel combustion, emits carbon as it is supplied to homes, commercial establishments and other energy users.

Transport

The second largest carbon-emitting source is the transport sector. This results from the fuels burned in diesel and petrol to propel cars, railways, shipping vehicles, aircraft support vehicles and aviation, transporting people and products from one place to another. The longer the distance travelled, the more fuel is used and the more carbon is emitted.

Business

This comprises carbon emissions from combustion in the industrial and commercial sectors, off-road machinery, air conditioning and refrigeration.

Residential

Heating houses and using electricity in the house, produce carbon dioxide. The same holds true to cooking and using garden machinery at home.

Agriculture

The agricultural sector also produces carbon dioxide from soils, livestock, immovable combustion sources and other machinery associated with agricultural activities.

Waste Management

Disposing of wastes to landfill sites, burning them and treating waste water also emit carbon dioxide and contributes to global warming.

Industrial Processes

The factories that manufacture and process products and food also release CO2 , especially those factories that manufacture steel and iron.

Public

Public sector buildings that generate power from fuel combustion also add to the list of carbon emission sources, from heating to other public energy needs.

Everybody needs energy and people burn fossil fuels to create it. Knowing how our energy use affects the environment, as a whole, enables us to take a step ahead towards achieving better climate.

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