How to Reduce Costs when Complying with SOX 404

Section 404 contains the most onerous and most costly requirements you’ll ever encounter in the Sarbanes-Oxley Act (SOX). In this article, we?ll take a closer look at the salient points of this contentious piece of legislation as it relates to IT. We?ll also explain why companies are encountering difficulties in complying with it.

Then as soon as we’ve tackled the main issues of this section and identify the pitfalls of compliance, we can then proceed with a discussion of what successful CIOs have done to eliminate those difficulties and consequently bring down their organisation’s IT compliance costs. From this post, you can glean insights that can help you plan a cost-effective way of achieving IT compliance with SOX.

SOX 404 in a nutshell

Section 404 of the Sarbanes-Oxley Act, entitled Management Assessment of Internal Controls, requires public companies covered by the Act to submit an annual report featuring an assessment of their company?s internal controls.

This ?internal control report? should state management’s responsibility in establishing/maintaining an adequate structure and a set of procedures for internal control over your company?s financial reporting processes. It should also contain an assessment of the effectiveness of those controls as of the end of your most recent fiscal year.

Because SOX also requires the public accounting firm that conducts your audit reports to attest to and report on your assessments, you can’t just make baseless claims regarding the effectiveness of your internal controls. As a matter of fact, you are mandated by both SEC and PCAOB to follow widely accepted control frameworks like COSO and COBIT. This framework will serve as a uniform guide for the internal controls you set up, the assessments you arrive at, and the attestation your external auditor reports on.

Why compliance of Section 404 is costly

Regardless which of the widely acceptable control frameworks you end up using, you will always be asked to document and test your controls. These activities can consume a considerable amount of man-hours and bring about additional expenses. Even the mere act of studying the control framework and figuring out how to align your current practices with it can be very tricky and can consume precious time; time that can be used for more productive endeavours.

Of course, there are exceptions. An organisation with highly centralised operations can experience relative ease and low costs while implementing SOX 404. But if your organisation follows a largely decentralised operation model, e.g. if you still make extensive use of spreadsheets in all your offices, then you’ll surely encounter many obstacles.

According to one survey conducted by FEI (Financial Executives International), an organisation that carried out a series of SOX-compliance-related surveys since the first year of SOX adoption, respondents with centralised operations enjoyed lower costs of compliance compared to those with decentralised operations. For example, in 2007, those with decentralised operations spent 30.1 % more for compliance than those with centralised operations.

The main reason for this disparity lies in the disorganised and complicated nature of spreadsheet systems.

Read why spreadsheets post a burden when complying with SOX and other regulations.

Unfortunately, a large number of companies still rely heavily on spreadsheets. Even those with expensive BI (Business Intelligence) systems still use spreadsheets as an ad-hoc tool for data processing and reporting.

Because compliance with Section 404 involves a significant amount of fixed costs, smaller companies tend to feel the impact more. This has been highlighted in the ?Final Report of the Advisory Committee on Smaller Public Companies? published on April 23, 2006. In that report, which can be downloaded from the official website of the US Securities and Exchange Commission, it was shown that:

Companies with over $5 Billion revenues spent only about 0.06% of revenues on Section 404 implementation
Companies with revenues between $1B – $4.9B spent about 0.16%
Companies with revenues between $500M – $999M spent about 0.27%
Companies with revenues between $100M – $499M spent about 0.53%
Companies with revenues less than $100M spent a whopping 2.55% on Section 404

Therefore, not only can you discern a relationship between the size of a company and the amount that the company ends up spending for SOX 404 relative to its revenues, but you can also clearly see that the unfavourable impact of Section 404 spending is considerably more pronounced in the smallest companies. Hence, the smaller the company is, the more crucial it is for that company to find ways that can bring down the costs of Section 404 implementation.

How to alleviate costs of section 404

If you recall the FEI survey mentioned earlier, it was shown that organisations with decentralised operations usually ended up spending more for SOX 404 implementation than those that had a more centralized model. Then in the ?Final Report of the Advisory Committee on Smaller Public Companies?, it was also shown that public companies with the smallest revenues suffered a similar fate.

Can we draw a line connecting those two? Does it simply mean that large spending on SOX affects two sets of companies, i.e., those that have decentralised operations and those that are small? Or can there be an even deeper implication? Might it not be possible that these two sets are actually one and the same?

From our experience, small companies are less inclined to spend on server based solutions compared to the big ones. As a result, it is within this group of small companies where you can find a proliferation of spreadsheet systems. In other words, small companies are more likely to follow a decentralised model. Spreadsheets were not designed to implement strict control features, so if you want to apply a control framework on a spreadsheet-based system, it won’t be easy.

For example, how are you going to conduct testing on every single spreadsheet cell that plays a role in financial reporting when the spreadsheets involved in the financial reporting process are distributed across different workstations in different offices in an organisation with a countrywide operation?

It’s really not a trivial problem.

Based on the FEI survey however, the big companies have already found a solution – employing a server-based system.

Typical server based systems, which of course espouse a centralised model, already come with built-in controls. If you need to modify or add more controls, then you can do so with relative ease because practically everything you need to do can be carried out in just one place.

For instance, if you need to implement high availability or perform backups, you can easily apply redundancy in a cost-effective way – e.g. through virtualisation – if you already have a server-based system. Aside from cost-savings in SOX 404 implementation, server-based systems also offer a host of other benefits. Click that link to learn more.

Not sure how to get started on a cost-effective IT compliance initiative for SOX? You might want to read our post How To Get Started With Your IT Compliance Efforts for SOX.?

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Field service and improved visibility

A manager is someone who has control over a company. They are given the responsibility of overseeing what the company does and making important decisions. The manager is the most important person in the empire and needs to be in the know at all times. Not what happened a day ago but in real-time and from any place.

Information is necessary for this to happen. It needs to be concise, brief and straightforward. Ideally, access to job status, location information, customer information, notifications and location information should be on the palms of their hands.

To sum it all up, there should be fluid communication among personnel in the field. Information should be accessed easily from one place as it flows to another to maintain steady two-way communication. This is possible with automation meaning that no amount of data will be left unseen or unused because of paperwork that was never handed over or looked into, reducing the chance of misinformation or missing information to a minimum.

Ways improved visibility will help your business through Field Service

Organisations using field services will agree that improved visibility has more business benefits and the real question is what aspect needs improving rather than discussing the benefits.

Real-time visibility

Managers need to be in the know from anywhere at any time. The manager needs information about the company. The need not to be physically present to have an idea of what’s going on. They should know everything at all times, from what was planned for the day to real-time events.

All this information should be easily accessed from one central point and should contain everything about the company and other relevant information.

Extending the back office into the field

This two-way communication is virtually irreplaceable. At any time, the information should flow among technicians in the field and those in the back office. This will help to have a better idea of how to manage the workload and come up with solutions to some work-related issues.

Everyone in the team should be informed and be up to speed about real-time events. Keeping everyone updated improves visibility because they can make updates and decisions based on the kind of information they get.

No more lost paperwork

Managing paper trail can be quite a hassle for organisations. With tons of workload, there can be many delays meaning that some information might be missed or forgotten. People might also choose not to turn up for work for days on end and can affect how much info is processed. Some work can be left undone, and work not invoiced.

When organisations use field service management services, information is fed only once and everything else is done automatically. Say goodbye to lags or relying on last month?s data. Work will move faster because people will have more time to focus on important things rather than chasing an endless paper trail.

Business intelligence

Field service management technology will let you know what is being done in the field and with such an abundance of data, will make sound decisions for the business.

Every decision is hinged on cold facts. Information needs to be easily accessed and filtered into the right categories so that sound business decisions are made from the collected data.

Growing revenue

The abundance of real-time information and improved visibility can determine whether a business will grow or not. Each piece of information can show trends that are critical for any business to improve. Trends show how each sector is doing and sheds more light into specific areas that need a total overhaul. This may include improving customer service, products on retail or hiring more technicians.

Without information, a company is one step closer to going out of business. Every action should be geared to increase the revenue and this starts by making the right choices.

Visibility when working offline

Working offline is an issue that can affect visibility. Sometimes agents will need to work in areas that have little network coverage or are deep down working in tunnels or are around heavy machines and turbines. Field service solutions are built for the mobile environment and for workers who may find themselves in non-connected areas so that they can still use their device while offline. This makes sure that there is no loss of information while working in-field

Time-saving

Certainly, business is constrained to its environments and if the demand changes it should prove to be flexible enough to adjust to changes as they happen. Field service solutions operations like schedule need to update instantly. Once activities start rolling, nothing should create lags in the schedule so that operations flow seamlessly at all time.

Field workers can then make updates and document changes easily on the job site directly on their device by using responsive site menus, drastically saving time while feeding data and complete orders.

Improved customer service

It is not a clich? to say that the customer is always right. With real-time information, both field service and back-office technicians can improve customer relations and satisfaction. With a unified system of sharing information like the ERPs and CRMs, the field officer can know more about specific clients, their history and other data to know more about what should be done in current and future orders. This means that better decisions will be made for each customer.

How improved visibility benefits different parts of the organisation

Improved visibility in all areas of the business makes information more accessible. Here are some of the benefits that various sects of a business can get from improved visibility.

? The business owner
The manager owns the company and can access all information with just a single tap. A lot of data can be used to analyse the health of the venture. This includes revenue, inventory, customer surveys, employee hours, invoices and customer data.
Profitability is increased by putting more emphasis on customer satisfaction and improving the quality of end products and services.

? The service manager
The service manager can see what is going on in the field in real-time, and look into measures that can improve the productivity of staff members in various departments.
And with workflow automation, time-saving is at the maximum because there is less paperwork consequently improving scheduling and job completion rates.

? Service administrator/ dispatcher
For the team in the office, they can assign tasks faster. Scheduling is automatically done and updated in real-time. It eliminates the need for paperwork and leaves more time to be productive on other errands.

? The field technician
Improved visibility for a field worker means that they can do their best in any task. They can share or get critical information about orders and customers. This drastically improves job completion rates and customer satisfaction.

? HR
Live information can be used to track certain orders, the time it takes to complete orders, and the number of staff required in the organisation. Such data can be used in HR to reduce payroll errors and erroneous overtime costs.

? Finance
Field service management software can also benefit the finance team by automation of invoices. A work order can be tracked from start to the end and invoiced immediately to retain faster payments. Relevant data can be used to track revenue and expenditures, and costs.

Real-time visibility gives a company many solutions to manage the workload. In the end, visibility is also useful in increasing revenue and a smooth transition of information for the company.

Project Management

In a cutthroat market, where the competition is constantly on the attack to break into your market share, implementing a project-based system can give your organisation the necessary tools to be more efficient and agile.

However, rapidly changing consumer demands, technologies and other factors make it ever more difficult to generate a strategic advantage from projects, let alone develop one. Also since a large organisation can easily end up having to manage multiple projects at the same time, the new management paradigm can appear too complex.

What your company really needs is the expertise that can guide you starting from conception and planning, down through procurement and execution in order to maximise whatever resources you have. Each move must be well thought out so that there are clear goals and objectives as well as methods to achieve them.

Programme Management

Are you running multiple projects pointing to an overall strategic direction? Then you’ll need more than just a “scaled-up” version of project management to make sure every component’s work effort is well coordinated to achieve your enterprise’s desired outcomes.

Through our expertise in programme management, we’ll work with your stakeholders, executives and clients to achieve the following:

Design a well-articulated management structure and clearly define decision-making roles & responsibilities – This will ensure decisions are made rapidly with zero to minimal overlapping issues and to promote a unified, well-synchronised advance towards the common objective.
Set objectives then make sure they are met by guiding your key personnel in coordinating activities across projects.
Design or utilise existing financial models such that they adhere to your enterprise’s financial policies.
Develop procedures for reporting expenditures specific to the programme.
Establish the programme infrastructure, including
- The appropriate technical environment and tools (e.g. hardware, software, communication, and other IT-related items)
- IT staff and administrators
Evaluate your enterprise’s current IT architecture to determine whether it will suffice to achieve your objectives. If it doesn’t, propose options you can take to meet what is required.
Plan out activities that should take place in different levels in the organisation.
Implement a periodic review of the programme progress as well as of interim results to ensure everything is aligned with the strategic outcome.

Programme and Project Reviews

Whether we’ve helped you set up your programme or you did it on your own, time will come when you’ll need to know whether everything is going as planned. If it appears like the entire programme is going smoothly, chances are, something’s going awfully wrong somewhere. Remember, even the most well-planned projects and programmes are still under the mercy of unforeseen variables.

We’ve got highly specialised reviews for either projects or an entire programme. We’ll be able to provide you answers to questions like:

Are all projects aligned with the programme’s intended direction?
Are the people working on your projects as focused with the business rationale as they have been with meeting deadlines and utilising resources?
Where are your risks and exposures? How can they be remedied?
Is the project viable at all?

We understand how your staff would want to function normally as quickly as possible. Rest assured, our programme and project reviews are conducted swiftly and efficiently so that both interruptions and oversights are brought to a minimum.

After we’re done, you can expect a detailed quantitative assessment of your programme and/or projects’ status.

Basically, we’re not here to find mistakes; we’re here to help you find ways to correct them. If a project rescue is required, we’ll be the first to lend a hand.

Project Rescue

Believe it or not, many of our clients approached us not before or during their project’s planning stages. But rather, after having gone through sloppy execution, when they end up losing control. In other words, we’re usually at the receiving end of the distress signal, after they’ve punched the panic button.

While obviously this isn’t the ideal time to seek the aid of any expert because it means you’ve incurred unnecessary losses already, all is not yet lost. If the appropriate remedial actions are taken in a timely manner, you can still achieve highly acceptable end results.

In fact, in most of our experiences with project rescue operations, we’ve been able to put projects back on track – just the way the planners wanted them to be. We’ll also help you devise airtight strategies to prevent your project from going astray again.

At the end of our project rescue,

You’ll regain complete control
Milestones will be reached as planned
Requirements will be accomplished, and
The project will be realigned with ideal business directions

Project Governance Processes

Constructing a firm underlying structure is essential in any organisation. So before we’ll institute project management, we’ll do the following first.

Set up a PMO or Project Management Office to ensure, among others, that
- Utilisation of facilities, budgets, technical support and other resources will be well coordinated
- Work products can be tracked and reviewed
- Issues regarding methodology and processes will be given appropriate attention
- Training can be organised
- Project management discipline be instilled in the IT department
Establish a steering committee to oversee the implementation of IT and business strategies
Fill up slots for a project manager, IT executive and a business sponsor and define the roles of each
Infuse project management practices to all affected units of the enterprise

Establishing PMOs, steering committees and other management structures is the easy part. Many organisations spend so much in order to create the structures related to project management, only to find out later that the effort has been all for naught. That’s why we won’t end there. Our objectives will therefore include the following:

To plant and cultivate an environment appreciative of project governance i.e. one that does not project it as just a bunch of bureaucratic processes and protocols.
To establish an organisational culture that starts at the top.
To make everyone involved understand that the power of project governance still lies in the hands of those who will ultimately implement it.

A project-driven enterprise is never propelled by a single project. Since multiple projects require a more complex governing structure, you’ll need to understand the intricacies of programme management.

Firewalls

There are two main reasons why some companies are hesitant to plug into the Internet.

They know they’ll be exposing their company data to outside attacks from malicious individuals and malware.
They fear their employees might get too many distractions: games, porn, chats, videos, and even social networking sites.

One vital component for your overall security strategy against such concerns? A firewall.

A firewall can block unauthorised access to certain Internet services from inside your organisation as well as prevent unauthenticated access from the outside. It is also used to monitor users’ activities while they were online.

In an enterprise setting, one may expect a collection of firewalls either for providing layered protection or segmenting off different units in the organisation. Some areas only need a standard line of defence while others require more restrictions. As such, certain firewalls may have different configurations compared to others.

Naturally, the more intricate an organisation’s defence requirements get, the more complex the task of monitoring, testing and configuring the firewalls becomes. That’s why we’re here to help.

We’ll evaluate your network as well as the security requirements of each department under your organisation to determine which firewall architecture is most suitable.
To achieve maximum efficiency, we’ll point out where each firewall should be positioned.
We’ll work with your key personnel to make sure all firewall configurations are set and optimised with your business rules in mind.
If a large number of firewalls are required, we’ll help you set up a firewall configuration management system.
Firewalls should be regularly tested and assessed to ensure they are in line with the organisation’s security policies. We’ll perform these routine tasks as well.

Firewalls aren’t very good at defending against sophisticated viruses. There are much better solutions for malware-related vulnerabilities, and we can help you in that regard too.

Other defences we’re capable of putting up include: