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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Mobile Workforce Management in a nutshell

It is fairly common for businesses to have staff working across many different locations across the country or even the world. Engaged in various activities like door-to-door sales, delivery and installations, service maintenance, conducting inspections & investigations or even data collection.

Managing and co-ordinating tasks, scheduling activities, planning and monitoring activities and communicating can often be challenging.

Mobile Workforce Management is the automation of the entire end-to-end workflow management and operations of any field service workers.

Mobile Workforce Management Synonyms

Mobile Workforce Management is also known as

Field Service Management
Job Scheduling Software
Job Management Software

Advantages of Mobile Workforce Management

It is increasingly clear that there needs to be a certain sense of discipline and streamlining of field operations and important to automate certain tasks within field sales and operations, primarily because it helps you to track your assets remotely and ensuring contact with your workforce when required. Enabling your team to get in touch when required.

Most importantly, engineers, sales representatives and customer care executives can easily send information, scan receipts, Invoice customers and retrieve other crucial information in a standardized and streamlined manner. Assisting in regulating your business and also bringing some order to what is usually a very chaotic mode of working.

Why choose Mobile Workforce Management

Work Force Management tools help you to stay in control. They assist in automating what can and should be automated leaving only the crucial human-human interactivity. Helping you to keep a record of all interactions and important data within a database, without you having to manually go through sales receipts, complaint slips and other such details.

A Field Force Management tool is a time-saver and efficiency tool for companies. Moreover, these tools help to automate several aspects of your day to day operations, leading to an increase in productivity and motivation.

Streamlining operations, will also ensure that important stakeholders are well informed and management visibility is enhanced. Helping your business to make smarter decisions and help serve your customers better.

Field Force Management is similar to an Enterprise Resource Planning (ERP) solution but is vastly different. It is specifically targeted at staff that work on the field and is intended to make their and your work more streamlined, transparent and easy to track.

Cloud based solutions help you automate

Field Force Management is usually cloud based which means all data is stored and accessible on secure cloud servers. There is no question of losing important data or not being able to retrieve something important. If something goes missing, there will usually be a backup available. Field force management tools include the software, the hardware and also the kind of training that is required for users to use it efficiently.

The software usually helps in saving and processing information while the hardware helps employees to enter important data into devices while they are on the job. Sometimes, field force solutions can also be a mobile app which negates the need for a specific or special device.

This is very important when it comes to field jobs as carrying different devices can prove to be a cumbersome job. At the end of the day, field force solutions are meant to reduce the burden on staff and not actually inadvertently increase it.

Denizon?s FieldElite Mobile Workforce management application provides significant improvements in efficiency and service with a switch to digital working and the elimination of paperwork.

All the information that is stored on the cloud can be run through analytics software so that you get the kind of reports that you are looking for to improve your business.

Field Force Management Process

A field force management tool helps you to remain in contact with your staff while they are at work on the field. This helps you to track your personnel in real time. Field personnel or your staff can log in and enter their attendance using a smartphone. You can assign that particular day?s task remotely using a web console or your own smartphone.

Next, they can carry out whatever duties they need to while you get all the alerts that you set to receive. This helps to increase transparency. You can choose to receive alerts on your phone or on your desktop.

Finally, staff can tag completed tasks with audio and images, instead of they having to type reports. This helps to focus more on the job than on job reporting. Last but not the least, location tags help you to ensure that the job is done at the right place. Your staff will not be able to take your generosity for granted.

All in all, a field force management tool helps you to track and control your staff without you having to be physically present with them and this is the beauty of this tool.

Summary

Field Force Management helps companies to reduce administration expense and improve productivity. This helps to automate data integration which is usually done with the help of cloud servers. Moreover, you can set invoice parameters that help you to also keep track of stocks, inventories and engage in P.O. and task management.

A number of field force management users also use it as a tool to engage in credit management. Banks and insurance companies particularly find this tool helpful as payments can be received on the job, instead of asking customers to pay online or offline. This also helps in building valuable customer relationships and enhance loyalty.

Thirdly, a field force management tool helps to increase planning efficiency. This means, you will be able to allocate tasks and optimize routing. All this helps to increase your ROI at the end of the day and get back the money you invest on field force management.

Finally, you will have more control over productivity and sales thanks to automation of data collection. You will also have more control over the execution of tasks and that will invariably make your company leaner and smarter.

Saving Energy Step 3 ? Towards a Variable Energy Bill

Do you remember the days when energy was so cheap we paid the bill almost without thinking about it? Things have changed and we have the additional duty of reducing consumption to help save the planet. This is the third article in our mini-series on saving energy. It follows on from the first that explored implementing a management system, and the second listing practical things to implement on the shop floor. These open up the possibility of the variable energy bill we expand on as follows.

If ?variable energy bill? sounds strange to you, I used the unusual turn of phrase to encourage you to view things in a different light. We need to move on from the ?pie chart? mentality where we focus on the biggest numbers like materials, facilities and labour, and zoom in on energy where we can achieve similar gains faster with less pain. But first, we need to see beyond the jargon that governments and consultants love, and get to grips with the reality that we can vary our energy bill and bring cost down.

As executives we recognise this, although other pressures distract us from accepting it as a personal goal. And so we delegate it down the organisation to a level where it becomes ?another crazy management idea? we have to follow to stay out of trouble. I read somewhere that half the world?s organisations do not have energy as a defined objective to monitor in the C Suite. No wonder commerce is only pecking away at energy wastage at a rate of 1% per year.

Find out where you are ?spending energy? and relate this to your core business. If there are places where you are unable to make a connection, challenge the activity?s right to exist. Following the energy trail produces unexpected benefits because it permeates everything we do.

Improved product design reducing time spent in factory
Streamlined production schedules reducing machine run times

Less wear on equipment reducing costly maintenance

A more motivated workforce that is prouder of ?what we do?

As you achieve energy savings you can pass these on in terms of lower prices and greater market share. All this and more is possible when you focus on the variables behind your energy bill. Run the numbers. It deserves more attention than it often gets.

2015 ESOS Guidelines Chapter 1 ? Who Qualifies

The base criteria are any UK undertaking that employs more than 250 people and/or has a turnover in excess of ?50 million and/or has a balance sheet total greater than ?43 million. There is little point in attempting to separate off high polluting areas. If one corporate group qualifies for ESOS, then all the others are obligated to take part too. The sterling equivalents of ?38,937,777 and ?33,486,489 were set on 31 December 2014 and apply to the first compliance period.

Representatives of Overseas Entities

UK registered branches of foreign entities are treated as if fully UK owned. They also have to sign up if any overseas corporate element meets the threshold no matter where in the world. The deciding factor is common ownership throughout the ESOS system. ecoVaro appreciates this. We have seen European companies dumping pollution in under-regulated countries for far too long.

Generic Undertakings that Could Comply

The common factor is energy consumption and the organisation’s type of work is irrelevant. The Environmental Agency has provided the following generic checklist of undertakings that could qualify:

Limited Companies	Public Companies	Trusts
Partnerships	Private Equity Companies	Limited Liability Partnerships
Unincorporated Associations	Not-for-Profit Bodies	Universities (Per Funding)

Organisations Close to Thresholds

Organisations that come close to, but do not quite meet the qualification threshold should cast their minds back to previous accounting periods, because ESOS considers current and previous years. The exact wording in the regulations states:

?Where, in any accounting period, an undertaking is a large undertaking (or a small or medium undertaking, as the case may be), it retains that status until it falls within the definition of a small or medium undertaking (or a large undertaking, as the case may be) for two consecutive accounting periods.?

Considering the ?50,000 penalty for not completing an assessment or making a false or misleading statement, it makes good sense for close misses to comply.

Joint Ventures and Participative Undertakings

If one element of a UK group qualifies for ESOS, then the others must follow suit with the highest one carrying responsibility. Franchisees are independent undertakings although they may collectively agree to participate. If trusts receive energy from a third party that must do an ESOS, then so must they. Private equity firms and private finance initiatives receive the same treatment as other enterprises. De-aggregations must be in writing following which separated ESOS accountability applies.