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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EU Energy Efficiency Directive & UK?s ESOS

In 2012 the European Union passed its EU Energy Efficiency Directive (EED) into law. This aims to reduce overall energy consumption by 20% by 2020. It placed an obligation on member states to pass back-to-back local legislation by June 2014.

EED Guidelines

The EED provides specific guidelines it expects member nations to address. The list is long and here are a few excerpts from it:

Large companies must use energy audits to identify ways to cut their energy consumption

Small and medium companies must be incentivised to voluntarily take similar steps

Public sector bodies must purchase energy-efficient buildings, products and services

Private energy-consumers must be empowered with information to help manage demand

Energy distributors / resellers must cut their own consumption by 1.5% annually

Legislators are free to substitute green building technology e.g. through better insulation

Every year, European governments must audit 3% of the buildings they own

Definition of Energy Audit

An energy-consumption audit is a question of measuring demand throughout a supply grid, with particular attention to individual modules and high demand equipment. While this could be an exercise repeated every four years to satisfy ESOS, it makes more sense to incorporate it into the monthly energy billing cycle.

Because energy use is not consistent but varies according to production cycle, this can produce reams of printouts designed to frustrate busy managers. ecoVaro offers an inexpensive, cloud-based analytic service that effortlessly accepts client data and returns it in the form of high-level graphic summaries.

Potential ESOS Beneficiaries

As many as 9,000 UK companies are obligated to do energy audits because they employ more than 250 employees, have a balance sheet total over ?36.5m or an annual turnover in excess of ?42m. Any smaller enterprise that finds energy a significant input cost, should also consider enlisting Ecovaro to help it to:

Obtain a better understanding of the energy side of their business

Achieve energy savings and share in a estimated ?3bn bonanza to 2030

Reduce carbon emissions to help meet their CRC commitments

More About ecoVaro

We offer web-based energy management software that helps you measure and manage energy costs. This strips data from your meters and generates personalised reports on a dashboard you control. This information helps you accurately zoom in on worthwhile opportunities. With Ecovaro on your side, ESOS truly becomes an Energy Saving OPPORTUNITY Scheme.

ecoVaro to tackle water stress

For many people within the UK, water is not really something to worry about. Surely enough of it falls out the sky throughout the year that it does feel highly unlikely that we?ll ever run out of it. There certainly does seem to be an abundance of Branded Water available in plastic bottles on our supermarket shelves.

Water, water, every where,
And all the boards did shrink;
Water, water, every where,
Nor any drop to drink.

The Rime of the Ancient Mariner ? Samuel Taylor Coleridge

Despite this, Once-unthinkable water crises are becoming commonplace. If you consider that In England and Wales, we use 16 billion litres of clean drinking water every day ? that’s equivalent to 6,400 Olympic sized swimming pools.

Currently, water companies can provide slightly more than we need ? 2 billion litres are available above and beyond what we’re using. In some areas, though, such as south east England, there is no surplus and, as such, these regions are more likely to face supply restrictions in a dry year.

If we take little moment to reflect on some of the most notable water related stories over the past few years, we’ll start to get a picture of just how real the potential and the threat of water shortages can be.

Reservoirs in Chennai, India?s sixth-largest city, are nearly dry right now. Last year, residents of Cape Town, South Africa narrowly avoided their own Day Zero water shut-off.

It was only year before that, Rome rationed water to conserve scarce resources.

Climate change is likely to mean higher temperatures which may drive up the demand for water (alongside population growth) and increase evaporation from reservoirs and water courses during spring and summer.

The impact of climate change on total rainfall is uncertain, but the rain that does fall is likely to arrive in heavier bursts in winter and summer. Heavier rain tends to flow off land more quickly into rivers and out to sea, rather than recharging groundwater aquifers.

A greater chance of prolonged dry periods is also conceivable. This combined with the harsh reality that no human population can sustain itself without sufficient access to fresh water.

If present conditions continue, 2 out of 3 people on Earth will live within a water-stressed zone by 2025

What is water stress?

Water stress is a term used to describe situation when demand for water is greater than the amount of water available at a certain period in time, and also when water is of poor quality and this restricts its usage. Water stress means deterioration in both the quantity of available water and the quality of available water due to factors affecting available water.

Water stress refers to the ability, or lack thereof, to meet human and ecological demand for water. Compared to scarcity, water stress is a more inclusive and broader concept.

Water Stress considers several physical aspects related to water resources, including water scarcity, but also water quality, environmental flows, and the accessibility of water.

Supply and Demand

Major factors involved when water scarcity strikes is when a growing populations demand for water exceeds the areas ability to service that need.

Increased food production and development programs also lead to increased demand for water, which ultimately leads to water stress.

Increased need for agricultural irrigation in order to produce more crops or sustain livestock are major contributors to localised water stress.

Overconsumption

The demand for water in a given population is fairly unpredictable. Primarily, based on the fact that you can never accurately predict human behaviour and changes in climate.

If too many people are consuming more water than they need because they mistakenly believe that water is freely available and plentiful, then water stress could eventually occur.

This is also linked to perceived economic prosperity of a give region. Manufacturing demand for water can have huge impact regardless whether water is actively used within the manufacturing process or not.

Water Quality

Water quality in any given area is never static. Water stress could happen as a result of rising pollution levels having a direct impact on water quality.

Water contamination happens when new industries either knowingly or unknowingly contaminate water with their industrial practices.

Largely, this can happen and frequently does so because these industries do not take effective control of monitoring and managing their impact on communal water supplies. Incorrectly assuming this is the responsibility of an additional third party like the regional water company.

The truth is, water quality and careful monitoring of it is all of our responsibility.

Water Scarcity

Simple increases in demand for water can in itself contribute to water scarcity. However, these are often preceded by other factors like poverty or just the natural scarcity of water in the area.

In many instances, the initial locations of towns or cities were not influenced by the close proximity of natural resources like water, but rather in pursuit of the extraction of other resources like Gold, Coal or Diamonds.

For Instance, Johannesburg, South Africa is the largest City in South Africa and is one of the 50 largest urban areas in the world. It is also located in the mineral rich Witwatersrand range of hills and is the centre of large-scale gold and diamond trade.

Johannesburg is also one of the only major cities of the world that was not built on a river or harbour. However, it does have streams that contribute to two of Southern Africas mightiest rivers – Limpopo and the Orange rivers. However, most of the springs from which many of these streams emanate are now covered in concrete!

Water Stress and Agriculture

Peter Buss, co-founder of Sentek Technology calls ground moisture a water bank and manufactures ground sensors to interrogate it. His hometown of Adelaide is in one of the driest states in Australia. This makes monitoring soil water even more critical, if agriculture is to continue. Sentek has been helping farmers deliver optimum amounts of water since 1992.

The analogy of a water bank is interesting. Agriculturists must ?bank? water for less-than-rainy days instead of squeezing the last drop. They need a stream of real-time data and utilize cloud-based storage and processing power to curate it.

Sentek?s technology can be found in remote places like Peru?s Atacamba desert and the mountains of Mongolia, where it supports sustainable floriculture, forestry, horticulture, pastures, row crops and viticulture through precise delivery of scarce water.

This relies on precision measurement using a variety of drill and drop probes with sensors fixed at 4? / 10cm increments along multiples of 12? / 30cm up to 4 times. These probe soil moisture, soil temperature and soil salinity, and are readily repositioned to other locations as crops rotate.

Peter Buss is convinced that measurement is a means to an end and only the beginning. ?Too often, growers start watering when plants don’t really need it, wasting water, energy, and labour. By accurately monitoring water can be saved until when the plant really needs it.

Peter also emphasises that crop is the ultimate sensor, and that ?we should ask the plant what it needs?.

This takes the debate a stage further. Water wise farmers should plant water-wise crops, not try to close the stable door after the horse has bolted and dry years return.

The South Australia government thinks the answer also lies in correct farm dam management. It wants farmers to build ones that allow sufficient water to bypass in order to sustain the natural environment too.

There is more to water management than squeezing the last drop. Soil moisture goes beyond measuring for profit. It is about farming sustainably using data from sensors to guide us.

Ecovaro is ahead of the curve as we explore imaginative ways to exploit the data these provide for the common good of all.

A Quarter of the World?s Population, Face High Water Stress

Data from WRI?s Aqueduct tools reveal that 17 countries ? home to one-quarter of the world?s population?face ?extremely high? levels of baseline water stress, where irrigated agriculture, industries and municipalities withdraw more than 80% of their available supply on average every year.

Water stress poses serious threats to human lives, livelihoods and business stability. It’s poised to worsen unless countries act: Population growth, socioeconomic development and urbanization are increasing water demands, while climate change can make precipitation and demand more variable.

How to manage water stress

Water stress is just one dimension of water security. However, like any challenge, its outlook depends on adequate monitoring and management of environmental data.

Even countries with relatively high water stress have effectively secured their water supplies through proper management by leveraging the knowledge they have garnered by learning from the data they gathered.

3 ways to help reduce water stress

In any geography, water stress can be reduced by measures ranging from common sense to innovative technology solutions.

There are countless solutions, but here are three of the most straightforward:

1. Increase agricultural efficiency: The world needs to make every drop of water go further in its food systems. Farmers can use seeds that require less water and improve their irrigation techniques by using precision watering rather than flooding their fields.

Businesses need to increase investments to improve water productivity, while engineers develop technologies that improve efficiency in agriculture.

Consumers can reduce food loss and waste, which uses one-quarter of all agricultural water.

2. Invest in grey and green infrastructure: D Data produced by Aqueduct Alliance – shows that water stress can vary tremendously over the year. WRI and the World Bank?s research shows that built infrastructure (like pipes and treatment plants) and green infrastructure (like wetlands and healthy watersheds) can work in tandem to tackle issues of both water supply and water quality.

3. Treat, reuse and recycle: We need to stop thinking of wastewater as waste.

Treating and reusing it creates a ?new? water source.

There are also useful resources in wastewater that can be harvested to help lower water treatment costs. For example, plants in Xiangyang, China and Washington, D.C. reuse or sell the energy- and nutrient-rich byproducts captured during wastewater treatment.

Summary

The data is undeniably clear, there are very worrying trends in water.

Businesses and other other organisations need to start taking action now and investing in better monitoring and management, we can solve water issues for the good of people, economies and the planet. We collectively cannot kick this can down the road any further, or assume that this problem will be solved by others.

It is time, for a collective sense of responsibility and for everyone to invest in future prosperity of our Planet as a collective whole. Ecological preservation should be at the forefront of all business plans because at the end of the day profit is meaningless without an environment to enjoy it in!

The Cloud: Changing the Game for Small Businesses

There is a consensus among cloud experts that the onset of cloud computing will benefit small organisations the most. In fact, many even go as far as saying that the cloud and small businesses are a match made in IT heaven. How much of this is true and how much of this is merely part and parcel of the hype surrounding cloud computing?

The Cloud as the Great?Equaliser

If you closely examine the essential characteristics of cloud computing, particularly public cloud services, you will see why small organisations would be very interested in the cloud, and would eventually flock to it, like moths to a flame. And why not? Cloud computing is turning out to be the weapon that can allow small and medium organisations to compete on a more level playing field against large enterprises.

Here are some cloud computing benefits that may just close the gap between the two.

Significantly lower IT spending. With little to no investment at all on hardware infrastructure and practically zero maintenance costs, SMBs that would have required substantial capital for IT are now finding it easy to get a business started from scratch or develop and test out new products by using the cloud as the backbone of their IT set-up. The pay-as-you-go pricing scheme that cloud computing offers allows companies to start small and scale up as needed, or when the revenue starts coming in.
Higher employee productivity. Licensing fees for software applications can run high even if you don’t have a large staff. Good thing there are now a host of cloud-based office tools – word processors, spreadsheets, presentations, accounting systems, etc. – that can boost employee productivity without the corresponding costs that small businesses can ill afford. Plus, team members in remote locations can continue to collaborate with the rest through any internet-connected device in real time.
Easier, better communication. The easy accessibility of communication apps has also changed the way employees interact with fellow employees and more importantly, with customers. Whether through email, instant messaging, or social networks, cloud services have given individuals and businesses more ways of giving and getting feedback. The best thing about it is that most of these services don’t cost much or are even free, giving SMBs ample tools to create better products and improve service.

A Look at the Figures Many small businesses are already seeing the potential in the cloud, with SaaS (Software as a Service) applications most commonly used among the early adopters. These services include email and other communication apps, file sharing, and backup.

In a February 2012 Edge Strategies survey (commissioned by Microsoft) of 3,000 small businesses in the US, the following data came to light:

The number of small companies with 2 to 10 employees using paid cloud services will triple in the next three years;
Current cloud users report purchasing an average of 4 services in the cloud now and expect to use 6 in the future;
Fifty percent agree that cloud computing is going to become more important for businesses such as theirs.

Further, a survey of 323 SMBs recently released by social business site Spiceworks and sponsored by EMC reveals that from 48 percent at the start of 2012 and 28 percent a year ago, 62 percent of the businesses surveyed now use some type of cloud app.

What these numbers show is that cloud adoption among small and medium enterprises is starting to gain ground and for sure, more will do the same as understanding and awareness increase. Yes, these businesses should still perform their due diligence as there is no one-size-fits-all cloud solution. But for those companies who have managed to find the right cloud apps and services for their needs, it’s all sunny skies up ahead.

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