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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Malware

In the past, viruses were created with the sole purpose of wreaking havoc on the infected systems. A large fraction of today’s malware, on the other hand, are designed to generate revenues for the creator. Spyware, botnets, and keyloggers steal information from your system or control it so that someone else can profit. In other words, the motivation for making them is now more attractive than before.

Keyloggers can reveal your usernames, passwords, PIN numbers, and other authentication information to their creators by recording your key strokes. This information can then be used for breaking into various accounts: credit cards, payment programs (like PayPal), online banks, and others. You’re right, keyloggers are among the favourite tools of individuals involved in identity theft.

Much like the viruses of old, most present day malware drain the resources, such as memory and hard disk space, of contaminated systems; sometimes forcing them to crash. They can also degrade network performance and in extreme cases, may even cause a total collapse.

If that’s not daunting enough, imagine an outbreak in your entire organisation. The damage could easily cost your organisation thousands of euros to repair. That’s not even counting yet the value of missed opportunities.

Entry points for malware range from optical disks, flash drives, and of course, the Internet. That means, your doors could be wide open to these attacks at this very moment.

Now, we’re not here to promise total invulnerability, as only an unplugged computer locked up in a vault will ever be totally safe from malware. Instead, this is what we’ll do:

  • Perform an assessment of your computer usage practices and security policies. Software and hardware alone won’t do the trick.
  • Identify weak points as well as poor practices and propose changes wherever necessary. Weak points and poor practices range from the use of perennial passwords and keeping old, unused accounts to poorly configured firewalls.
  • Install malware scanners and firewalls and configure them for maximal protection with minimal effect on network and system performance.
  • Implement regular security patches.
  • Conduct a regular inspection on security policy compliance as well as a review of the policies to see if they are up to date with the latest threats.
  • Keep an audit trail for future use in forensic activities.
  • Establish a risk management system.
  • Apply data encryption where necessary.
  • Implement a backup system to make sure that, in a worst case scenario, archived data is safe.
  • Propose data replication so as to mitigate the after effects of data loss and to ensure your company can proceed with ‘business as usual’.

Once we’ve worked with you to make all these happen, you’ll be able to sleep better.

Other defences we’re capable of putting up include:

Fine-tuning your Operations and keeping our staff Happy with FieldElite

They are the engine that drives your operations, but are you really giving you value for your money? How much time is spent by your personnel on lengthy paperwork and record-keeping, as opposed to actually providing the service to your customers? Manual tasks create bottlenecks and slow your operations, which in turn affects service delivery and customer satisfaction. You want to reach more clients and boost your brand image, growing your market share and generating more revenue. Field Service Management (FSM) software comes in optimise the operations of your mobile workforce, cut down resource wastage, and enhance your productivity as a firm, by actually enabling your field staff to get more done, thus achieving their individual goals. In fact, according to a report published by Fortune Business Insights?, the global FSM market- which stood at $2.29 billion as recently as 2018, will have expanded to $7.27 billion by 2026. What does this mean for your employees, and how do they benefit from FieldElite?

  • Skipping the paperwork with end-to-end automation

Filing reports, keeping track of equipment used, working on the Excel sheets for multiple jobs on a daily basis, all through to the routing and billing- it can be a logistical nightmare. It’s not just about the hours spent poring through documents and typing away at calculators. Manual work exposes you to the risks of human error. Missing records, inaccurate assessments of the situation on the ground due to the overwhelming data streaming in, putting the head office staff under strain- it all hampers the productivity of the company. 

Take scheduling for instance. You have different employees, and various jobs that need their attention, at different locations. It can be a plumbing company whose clients have water filters that need to be repaired, gas boilers inspected, leaking pipes fixed, and others who need new installations to be set up. Assigning your personnel to the different situations will need to take into account the type of job, and the amount of time that it will require, aspects such as the location and the crew that is closest to it. At the head office you will want to keep tabs on the jobs that are in progress, pending, complete, those on hold, and even those that have been cancelled. Running all these through traditional manual processes is enough to drive you to the edge. What’s more, tasks that slip through your fingers amidst the confusion will result in negative feedback from your customers- which you don’t want hitting your brand.

With a field service job management software like FieldELite, you get to handle it all from one dashboard. Optimise your service delivery using the accurate scheduler, that allows you to account for the location of your employees, the status of the job- from the urgent ones like emergency tasks, to the normal duties such as routine maintenance, and low-priority tasks. The field service scheduling software comes with a real-time location feature that allows you to determine the employees closest to the client’s premises who will be appropriate for the job, map out the service areas and give you a birds-eye view of all the operations on the ground, while being updated with the progress of each specific task. Less time is spent travelling to- and from the central office, and more on actually tending to your client’s needs. You can even have situations where you can assign end-of-day tasks to employees who will be passing on that route on their way home.

  • Enhanced resource utilisation that promotes personal and professional development

Skill is key across the industries- from electrical services, solar panel installation, landscaping, home remodelling, pest control, plumbing, HVAC system maintenance, to construction and property management. For the job to be done appropriately and make your clients happy, you want to assign the task to an employee who is particularly proficient at it. This tends to be glimpsed over during manual scheduling since the personnel at the head office will be swamped with so many files, and will pick the first one that comes close to fitting the job description, leading to overlapping of roles. Sure, they may get it done, having seen their colleagues do it and even helping them out when they worked together before on similar projects- but will it be up to the required standard? On the other hand, the FSM allows you to ensure that you get the right technician for the task- who will be more motivated, boosting their performance.

What about accidents? Your employees want to feel safe as they go about their mandate. Many of the field service jobs are hazardous- such as electrical repair jobs, window cleaning tasks at high rise buildings, to elevator repair jobs where a slight glitch can lead to severe ramifications. Field service management software also comes in handy here, where the head office can be notified of any emergency the moment it occurs, and arrange for the necessary action to be taken immediately. That way, your employees will not feel neglected while they are out in the field, showing them that their safety is a priority to your business- which in turn increases their morale. 

  • Readily available knowledgebase and feedback system

When the employees have been assigned a specific job, they will require certain information about it. This includes the scope of the task, history of previous repairs or maintenance that was carried out, accompanying images if needed, risk assessment, any hazards or contaminants that they will need to prepare for, to notes left by technicians who had handled it. Having to keep checking their email, or picking up documents at the office for the day’s job and walking around with them all day as they tend to one customer after another, will slow things down, and not to mention frustrate them. However, the FSM system is directly accessible by the employees via app on their phones. The information needed for each specific task will thus be at their fingertips, speeding up the process and ensuring that they will be ready for each project being handled. 

While carrying out the job itself, the employees will use the very same app to update the system on how it is progressing, chat with the staff at the head office, update the inventory and even place orders for extra parts if necessary. Since mobile service management software apps like FieldElite also work in offline mode, the photos, reports and other entries that are made are collected by the app and saved on the device. Once a network connection is established, they are then updated to the central database- thus ensuring that the job can proceed regardless of the location. 

Once the job is completed, the customer input is also taken, registered in the system through their e-signature. A signoff comment included gives the customer the opportunity to indicate their experience with the job, and the feedback that they would like to provide. In case the job has not been completed, then the scheduling software kicks in, putting it in queue for another appointment to take care of the task, or resolve the issue that had caused it not to be completed the first time. The completed tasks head right to invoicing, which is also handled within the field service management platform, making it a seamless task for the head office staff.

Strategy and Portfolio Management

 

A well planned strategy is the necessary bridge between brilliant leadership and excellent execution. Without it, your entire organisation cannot hope to respond quickly and effectively to challenges and changes within the landscape on which it operates.

Strategic planning involves identifying objectives, understanding what resources are needed to attain them, and then allocating the resources to the appropriate units to ensure they are used optimally towards the achievement of desired objectives. Among the end results which can be reflected by your team members are:

  1. Deeper understanding of the competitive environment;
  2. Snappy execution of plans;
  3. Faster, more aligned actions; and
  4. More intelligent and apt responses against strategic moves of the competition.

We understand the need to institute strategic management in such a way that your organisation can easily adapt to unforeseen developments. As such, all our solutions are formulated to make your organisation not only well-guided but also as dynamic as possible.

Strategy Formulation

Before you can proceed to map out any strategy for your company, you’ll have to study your company’s current environment. This will help you determine what courses of action should be taken to be able to navigate through such environment on your way to the end goal.

If you’re not a full time strategist, such a task can either be very daunting or deceivingly easy… the former can prevent your team from getting started, while the latter can lead your team astray.

Ideally, strategy formulation should be carried out as quickly and as efficiently as possible so you can move on to implementation before the competition can react. Our methods can enable your leaders to hit the ground running each time they set out on a strategic plan.

How?

  • We can assist in accurately applying strategic tools like SWOT and Gap analysis, then help integrate the results into an effective strategic plan.
  • We’ll train your team how to carry out effective research techniques so that the information they gather will really be what we need. This is because the tools mentioned earlier can only work effectively if the inputs were picked intelligently. Of course, if you want the entire process expedited, we can also conduct the research ourselves.
  • We’ll establish best practices for top-down, bottom-up, and collaborative strategic management processes. We’ll even show you how to organise and hold meetings where team members are constantly engaged and in-sync, so action plans can be developed and relayed fast.
  • We’ll see to it that strategies for all functional departments (such as IT management, supply-chain, HR, marketing, and legal) are in line with your business strategies, which should in, turn be aligned with your overall corporate strategy.

Strategy Evaluation

Your strategies have to be periodically assessed if you want to determine whether they are attuned to variations affecting your organisation. These changes may include new technologies, emerging competitors, new opportunities, as well as unexpected developments in the economic environment and political climate.

While no time limit is imposed for the build-up of resources vital to the attainment of a specific objective, the window of opportunity can shut on you before you can start amassing such resources. Given this possibility, it is important for your strategies to undergo evaluation processes that will determine whether you should pursue them or not.

Using only the most reliable evaluation techniques, we’ll help you establish whether:

  • Your strategies will place your company in a position that will give it competitive advantage or will erode whatever advantage the competition already has;
  • Your strategies are consistent with the landscape on which your company currently traverses;
  • They are realistic enough in relation to the resources you have on hand;
  • The associated risks have all been identified and the appropriate control measures have already been put in place;
  • The time frames for their full realisation are both realistic and acceptable.

Portfolio Management

In today’s highly competitive market, many of the more successful enterprises are driven by project-based systems.

Now, there’s always a tendency for project managers to become overenthusiastic and to come up with a number of projects that can’t be sustained by available resources. If your project-based company frequently runs out of resources, then either you just have too many projects running or too much is being allocated to a select few.

In both instances, the problem does not necessarily lie on the individual project managers themselves. Rather, what is needed is the ability to have full control over existing projects and investments.

Your leadership should be able to rank projects in terms of their impact to your organisation’s growth, positioning, and profitability. This will give you sufficient information when deciding which projects to pursue, prioritise, or shut down. These are the benefits you’ll gain from our services:

  • A vivid presentation of the big picture. Only when you can step back from all the detail and see the interplay of investments and resources will you be able to make wise decisions regarding how and where to position them.
  • The ability to distinguish between projects with the highest potentials and those that are outdated.
  • Access to expertise that will help you distribute your present IT infrastructure, human resources, financial resources, and facilities across running projects to obtain the biggest benefits for all stakeholders.

Contact Us

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  • (+44)(0)20-7193-9751 – UK

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