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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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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What Kanban can do for Call Centre Response Times

When a Toyota industrial engineer named Taiichi Ohno was investigating ways to optimise production material stocks in 1953, it struck him that supermarkets already had the key. Their customers purchased food and groceries on a just-in-time basis, because they trusted continuity of supply. This enabled stores to predict demand, and ensure their suppliers kept the shelves full.

The Kanban system that Taiichi Ohno implemented included a labelling system. His Kanban tickets recorded details of the factory order, the delivery destination, and the process intended for the materials. Since then, Ohno?s system has helped in many other applications, especially where customer demand may be unpredictable.

Optimising Workflow in Call Centres
Optimising workflow in call centres involves aiming to have an agent pick up an incoming call within a few rings and deal with it effectively. Were this to be the case we would truly have a just-in-time business, in which operators arrived and left their stations according to customer demand. For this to be possible, we would need to standardise performance across the call centre team. Moving optimistically in that direction we would should do these three things:

  • Make our call centre operation nimble
  • Reduce the average time to handle calls
  • Decide an average time to answer callers

When we have done that, we are in a position to apply these norms to fluctuating call frequencies, and introduce ?kanbanned? call centre operators.

Making Call Centre Operations Nimble
The best place to start is to ask the operators and support staff what they think. Back in the 1960?s Robert Townsend of Avis Cars famously said, ?ask the people ? they know where the wheels are squeaking? and that is as true as ever.

  1. Begin by asking technical support about downtime frequencies, duration, and causes. Given the cost of labour and frustrated callers, we should have the fastest and most reliable telecoms and computer equipment we can find.
  1. Then invest in training and retraining operators, and making sure the pop-up screens are valuable, valid, and useful. They cannot do their job without this information, and it must be at least as tech-savvy as their average callers are.
  1. Finally, spruce up the call centre with more than a lick of paint to awaken a sense of enthusiasm and pride. Find time for occasional team builds and fun during breaks. Tele-operators have a difficult job. Make theirs fun!

Reducing Average Time to Handle Calls
Average length of contact is probably our most important metric. We should beware of shortening this at the cost of quality of interaction. To calculate it, use this formula:

Total Work Time + Total Hold Time + Total Post Call Time

Divided By

Total Calls Handled in that Period

Share recordings of great calls that highlight how your best operators work. Encourage role-play during training sessions so people learn by doing. Publish your average call-handling time statistics. Encourage individual operators to track how they are doing against these numbers. Make sure your customer information is up to date. While they must confirm core data, limit this so your operators can get down to their job sooner.

Decide a Target Time to Answer Calls
You should know what is possible in a matter of a few weeks. Do not attempt to go too tight on this one. It is better to build in say 10% slack that you can always trim in future. Once you have decided this, you can implement your Kanban system.

Introducing Kanban in Your Call Centre Operation
Monitor your rate of incoming calls through your contact centre, and adjust your operator-demand metric on an ongoing basis. Use this to calculate your over / under demand factor. Every operator should know the value on this Kanban ticket. It will tell them whether to speed up a little, or slow down a bit so they deliver the effort the call rate demands. It will also advise the supervisor when to call up reserves.

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Key Steps to Complying with ESOS

Energy Savings Opportunity Scheme has already been launched. In fact, it is by now in its initial phase. However, many businesses are still not aware of the new scheme, especially those who are covered by the qualifications for ESOS. To help them understand what they need to do in compliance to the energy efficiency strategy, here are key steps they can follow along the way.

Measure Overall Energy Consumption

The first step to complying with ESOS is to make an initial estimate of the business? energy consumption. This includes measuring the use of electricity, renewable energy, combustible fuels and all other forms of energy consumed whether in buildings, transports and industrial processes.

Three important factors to consider are the measurement units used, the reference period and quality of data. Energy units, such as MWh and GJ, or energy expenditure costs should be applied. Business enterprises should also do the initial measurement within a reference period of 12 months. Moreover, data collected should be verifiable at hand.

Identify Areas of Significant Energy Consumption

When the total energy consumption for all the activities and assets has already been estimated, it’s then time to identify what areas in the organisation comprise the significant portion of the overall energy usage. The areas recognised should cover at least 90% of the overall consumption. Meaning to say, ESOS participants have the chance to omit 10% of the energy consumption and instead focus on the 90%. This would ensure that subsequent energy audits will be cost-effective and proportionate.

Consider and Choose Compliance Routes

In order to comply with ESOS, qualified businesses should consider what compliance routes to take. These routes include taking series of energy audits, operating and implementing a certified ISO 50001 energy management system, acquiring Display Energy Certificates (DECs) and working with Green Deal assessments. Whichever route the business takes, one should maintain credible evidences, along with helpful documents, to certify their compliance.

Report the Compliance

Except when the large enterprise covers all the significant areas of energy consumption by means of ISO 50001 certification, one should appoint a lead assessor to supervise, conduct and review the organisation’s chosen ESOS compliance route. In this case, the approved assessments should then be signed off at board level to ensure that the conclusions and recommendations for energy savings are properly carried. To confirm their compliance, the business should submit a formal notification to the Environment Agency.

Because ESOS is not just an opportunity but also an obligation, it designated compliance bodies and gave them the authority to file civil penalties towards those who fail to comply with the scheme. Not only that, these appropriate authorities have the right to publish information about non-compliant enterprises including their name, details of non-compliance and corresponding penalty amount. Among these UK compliance bodies are Natural Resources Wales, Environment Agency in England, The Scottish Environment Protection Agency (SEPA) and Northern Ireland Environment Agency.

So, if you are covered with the ESOS qualifications, make sure to be informed. As the famous saying goes, ?Ignorance of the law excuses no one.? Likewise, awareness of ESOS is a responsibility every large business in UK should give importance to.

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