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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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!

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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IT Risk and Control Solutions Specialists – Why you need them more than ever

Over the years, the capabilities of IT systems have certainly grown by leaps and bounds. But so have the risks that accompany them. Countless threats to IT systems now exist that are capable of seriously disrupting business operations. That’s why companies have to conduct assessments aimed at making sure their systems are still capable of functioning effectively, efficiently, and securely all the time.

If you think you’ve been lucky enough to be spared from these threats, then maybe it’s because you haven’t conducted a risk assessment on your IT system recently. All too often, we hear of CIOs who believed their IT system was in tip-top condition, only to be later caught off-guard by a critical system breakdown that would eventually cripple their business for days or weeks.

More information assets to look after

If, before, you only had to worry about regular office applications, workstations, a LAN and a server, today’s varied and more sophisticated information assets are more challenging to maintain.

In addition to network operating systems, database management systems, content management systems, email systems, virtualization platforms, document management systems, business intelligence applications, and accounting software, a typical enterprise may also have to look after firewalls, intrusion detection systems, storage and backup systems, and data loss prevention systems, to mention a few.

These understandably require the services of experts spanning a wide range of skill sets.

Rising threats to corporate identity and privacy

Individuals are no longer just the ones being preyed upon by identity thieves. Businesses can now be subject to corporate identity theft as well. You could wake up one day finding your business already accused of carrying out illegal activities, a big chunk of your money gone, and your directors? seats already occupied by complete strangers.

To make things worse, corporate threats aren’t just coming from the outside.

Threats to corporate privacy, for instance, can come from within the organisation itself. Sensitive information like trade secrets and financial data are often leaked out (purposely or inadvertently) by employees. This is largely caused by the ever growing number of options for communications and transferring data (e.g. emails, instant messaging, blogs, social networking sites, ftp, P2P, etc.).

Greater challenges in designing, developing, and implementing policies and programs

Laws and regulations like SOX and Solvency II, which have direct impacts on IT, are on the rise. That is why corporate policies and programs now require sweeping changes. You now have to be more deliberate in integrating IT when establishing governance, internal controls, change management, incident management, and performance management.

A solid understanding on widely accepted frameworks and good practices like COBIT, COSO, and CMMI will help you considerably in such undertakings. Using these frameworks as guidelines will not only help you keep your policies and programs attuned to the times, they will also keep you in compliance with regulations.

Increasing demand for disaster recovery and business continuity capabilities

Every time you have a down time, you increase the probability of losing your customers to competitors. The longer the down time, the greater that probability becomes. Therefore, when a major disruption strikes, you should be able to recover at the soonest. If possible, you should be able to deliver products and services as usual.

This of course requires spending to increase your disaster recovery (DR) and business continuity (BC) capabilities. Are you ready for it? Migrating your IT infrastructure from traditional systems to the latest technologies that are better equipped for BC/DR requires careful planning and implementation to ensure an optimal return on investment.

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