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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Implementing Large-Scale Complex Business Change

Sometimes, driving your people to work harder is not enough for your organisation to withstand the pressures laying siege to it. With uncertain economic conditions, unpredictable fresh competition, and looming threats from the environment or even pandemic-grade diseases, empowering your people to not only ‘think’ but also to ‘step’ out of the box is currently the name of the game.

However, such initiatives typically require sweeping changes throughout your entire organisation … and to think even the slightest change is often met with hard resistance.

Whether you’re about to undergo an M&A, relocate due to a major catastrophe, scale down to a skeletal workforce, or implement a brand-new company-wide strategy, our systematic approach to large-scale complex business change can help you make the transition as seamless as possible.

We understand the importance of the human aspect in change management. That is why we’ll focus on making your people appreciate the benefits of having to learn new skills, perform new tasks, employ modern technologies, and go through new processes in order to tone down the resistance level.

Our entire process spans from top to bottom, wherein we’ll start with your sponsors, down to your managers, and then to other stakeholders in making them appreciative of the needed changes and in order to achieve alignment with your organisation’s goals. Our top to bottom approach is also aimed at casting a positive “shadow of the leader” on people down the line, enabling them with an optimistic view despite the gruelling tasks before them.

We invite you to have a look at the steps we take in implementing large-scale complex business change to win over a strong and lasting commitment to it.

Evaluating the Required Change

Large-scale complex business change initiatives can be implemented expeditiously and economically if you’ve clearly defined the scope of the change as well as the forces that shape your organisation. You’ll want to know which areas yield easily and which are hard to change to determine where and how you’re going to focus more of your efforts on.

To arrive at a sound and systematic plan, we first gather as much information as needed and analyse them. We determine whether your departments have the required capabilities and how we can arrive at a clear organisational alignment. That way, we don’t waste time, effort and resources when the moment comes to carry out the plan.

These are some of the diagnostic procedures we perform in evaluating the required change.

Change complexity analysis. We’ll assess the contribution of people and task factors to the overall complexity of the change project. This will help us determine how to approach the problem efficiently.
Causal analysis. By establishing cause and effect relationships, we can identify root or circular causes. This will allow us to pinpoint problem areas and prevent a repetition of past mistakes.
Structural analysis. Any company is propped up by a number of structures: organisational, process, motivational, social, and physical, among others. Understanding the structures that drive, motivate, hamper, connect, and influence your people’s behaviours can provide insights as to how or where structural change can best be executed.
Context analysis. We’ll look into market forces as well as political, economic, social, technological, legal, and environmental factors enveloping your business. We’ll also analyse your driving objectives, organisational alignment, and organizational capabilities. By analysing the internal and external environment in which your business currently operates, we can formulate a customised strategic and effective plan of action.

Managing Stakeholders

Change initiatives won’t prosper without total commitment from all stakeholders. Stakeholders refer to people in your organisation who either have interests in the change project or can be affected by it.

We deal with your stakeholders starting from the top because if we can’t gain full commitment from those already in the best position to spur the diverse entities in your company into active cooperation, striving to secure commitment from other areas will be futile.

That is, if you don’t have the full support of your key and principal sponsors, i.e. the people who have the biggest say and have greatest control over resources in your organisation, you can’t hope to sustain the change endeavour, let alone provide the much needed spark to get it started.

Here’s how we carry out our stakeholder management actions.

Conduct research to identify all stakeholders: the sponsors, your internal and external partners, the main targets of the change, and all interested parties. That way you can “switch on” implementors of each change action in the proper sequence.
Not everyone will offer resistance to your change endeavours. We’ll help you identify those stakeholders and sponsors who are willing to offer support, evaluate the level of support they are willing to give, harness all available supports and utilise them extensively to benefit the change.
Gain a deeper understanding as to why certain stakeholders are willing to lend support. In doing so, we can implement the right strategies that will encourage them to continue supporting you.
Assemble a leadership team that will champion your change initiatives. We’ll facilitate effective collaboration among its team members, transforming them into a cohesive force designed to carry out plans and motivate everyone else down the line.
Upon realisation of the change project, we’ll see to it that all stakeholders get a taste of the carrot at the end of the stick. This will encourage them to continue active cooperation in future change initiatives.

Planning for the Change

Anyone who has experienced having their car stuck in the mud knows that stepping on the accelerator will only get the vehicle trapped even deeper. Without the aid of a towing truck, getting the car out will require careful planning since different combinations of pulling, pushing, lifting, rocking to-and-fro, and stepping on the accelerator may be needed.

Of course, some combinations are just better than others. The same principle holds when effecting change.

Our approach to change management typically varies depending upon the information we obtain from the different analyses performed earlier. For instance, since not all organisations are suitable for a collaborative approach, we will employ either collaborative, consultative, directive, or coercive change management strategies wherever applicable.

A well-planned change will result in a smoother, less costly, and less disruptive transition. Here’s how we’ll help you plan your change initiatives.

When put in a predicament similar to the car-in-the-mud, the basic strategy entails identifying the current resisting forces and predicting what other resisting forces may be encountered along the way. After researching and pointing out your organisation’s resistance forces, we’ll lay out the most appropriate facilitation, education, and negotiation techniques.
To bring down wastage to the lowest possible levels, we’ll engineer a change delivery plan that involves the most cost-effective sequence of driver, process, technology, organisational, and people alignment.
To win and maintain a high level of trust, confidence and commitment from all sponsors and stakeholders, we’ll present a clear road map of the change process as well as landmarks that will prove how far we will have gone. These landmarks will then be brought to each sponsor’s and stakeholder’s attention each time they are arrived at in order to build up assurance and continued commitment.
We’ll design measurement tools and schedule reporting deadlines so that you’ll know what to look forward to and when to expect them.

Managing the Change

Your company will hold a better chance of maintaining a sizeable lead over the rest of the pack if you constantly establish a rally point and instil in your stakeholders the drive to rally to that point from the get-go. To make this happen, your company must undertake the unfreezing, transition, and refreezing phases of change skilfully in order to bring all stakeholders into the right mindset.

Our specialists’ systematic and efficient methods for each of these phases are designed to simplify the management of each phase as well as provide a seamless shift from one phase to the next. This is what we’ll do:

Set up a change project management office to ensure that everything associated with the change initiative is given the needed attention and resources even while all the other usual processes in your organisation run concurrently.
To unfreeze your people and get them started on the road of change, we’ll employ unfreezing techniques wherever they are most appropriate. We’ll resort to different kinds of methods ranging from presenting persuasive evidence justifying the need for change to showing a motivational vision for inspiring your people to embark on the change process.
Since it is during the transition phase when your people can find themselves groping in the dark, we’ll offer executive coaches for your senior managers; facilitators to provide guidance during team meetings and other change activities; coaches to educate and inspire them to meet the change with the right attitude; trainers to teach new systems, procedures, and technologies; as well as employ a variety of other techniques in order to make the transition phase as seamless as possible.
Although your people should always be ready to undertake the next major change after a previous one, there should be points in between where they can taste the spirit of success, establish a temporary base to rejuvenate, and immediately gain a deeper understanding of the nearby terrain so as to envision the next rally point. We’ll see to it that this vital phase of change is carried out completely.

How Mid-South Metallurgical cut Energy Use by 22%

Mid-South in Murfreesboro, Tennessee operates a high-energy plant providing precision heat treatments for high-speed tools – and also metal annealing and straightening services. This was a great business to be in before the energy crisis struck. That was about the same time the 2009 recession arrived. In no time at all the market was down 30%.

Investors had a pile of capital sunk into Mid-South?s three facilities spread across 21,000 square feet (2,000 square meters) of enclosed space. Within them, a number of twenty-five horsepower compressors plus a variety of electric, vacuum and atmospheric furnaces pumped out heat 27/7, 52 weeks a year. After the company called in the U.S. Department of Energy for assistance, several possibilities presented.

Insulate the Barium Chloride Salt Baths

The barium chloride salt baths used in the heat treatment process and operating at 1600?F (870?C) were a natural choice, since they could not be cooled below 1200?F (650?C) when out of use without hardening the barium chloride and clogging up the system. The amount of energy taken to prevent this came down considerably after they covered and insulated them. The recurring annual electricity saving was $53,000.

Manage Electrical Demand & Power

The utility delivers 480 volts of power to the three plants that between them consume between 825- and 875-kilowatt hours depending on the season. Prior to the energy crisis Mid-South Metallurgical regarded this level of consumption as a given. Following on the Department of Energy survey the company replaced the laminar flow burner tips with cyclonic burner ones, and implemented a number of other modifications to enhance thermal efficiency further. The overall natural gas reduction was 20%.

Implement Large Scale Site Lighting Upgrade

The 24/7 nature of the business makes lighting costs a significant factor. Prior to the energy upgrade this came from 44 older-type 400-watt metal halide fixtures. By replacing these with 88 x 8-foot (2.5 meter) fluorescent fittings Mid-South lowered maintenance and operating costs by 52%

The Mid-South Metallurgical Trophy Cabinet

These three improvements cut energy use by 22%, reduced peak electrical demand by 21% and brought total energy costs down 18%. Mid-South continues to monitor energy consumption at each strategic point, as it continues to seek out even greater energy efficiency in conjunction with its people.

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Benefits of Integrating IoT and Field Service

Owing to the complexity of its definition, many people loosely use the phrase Internet of Things (IoT) without having a solid grasp of its true meaning. A majority in this category take IoT to be nothing more than the automation of home gadgets, where the internet is used to interconnect computing components embedded in everyday devices.

Granted, the whole idea of IoT got its roots from the home setting. Nevertheless, IoT has outgrown that spectrum and has since penetrated into almost every area of business and industry. By employing IoT, you can literally take full control of everything in your business using a single device. From assigning tasks to monitoring security, managing bills to tracking time, IoT has revolutionized the way business is done.

Interestingly, not so long ago, most technology experts limited their forecasts to machine-to-machine (M2M) integration and Augmented Reality (AR), which also, admittedly, hit the technology industry with an admirable suave. Back then, it could have been laughable for anyone to have suggested that IoT would be so commanding in almost every industry, including real estate, medicine, automobile, and more.

It’s not for nothing, therefore, that the field service industry has also embraced IoT, integrating it in the daily running of business activities, including tracking machine diagnostics, detecting breakdowns, and assigning field engineers to attend to customer needs.

How the Field Service Industry is Benefiting from IoT

Machine uptime has remained an ongoing concern for many customers. In the traditional approach, whenever a machine breaks down, the customer alerts the service provider and then the field service manager checks to see if there is any field engineer available for a new task. Once an engineer has been identified, he?s then dispatched to the site. This worked, but it resulted in an extended machine downtime, a terrible experience for customers.

Thanks to IoT, things are now happening differently.

IoT is now integrating machines to a central communications centre, where all alerts and status updates are sent. The notifications are instant. The field service manager, therefore, gets to learn of the status of machines at the exact time of status change. An engineer who?s not engaged would then be immediately assigned to undertake any needed servicing or repair.

By employing IoT, the service provider receives timely reports relating to diagnostics, machine uptime, part failures, and more. The field manager can, as a result, foretell and forestall any possible downtime.

How has this been helpful?

Before giving a definite answer to that question, it’s crucial to note that more than half of all field service organizations now employ IoT in their Asset Management Systems and Field Service Management. And to answer the question, all the organizations that have the two systems integrated using IoT experience twice as much efficiency as those that don’t, states an Aberdeen Group report. As you already know, improved efficiency results in a corresponding upshot in customer satisfaction.

Apps Making a Difference in IoT-Field Service

The integration of IoT into almost every aspect of business prompted the design and development of different applications to link computing devices. Since the advent of IoT, the software development for the technology has come of age. Powerful and lightweight apps that don simple yet beautiful user interfaces are now readily available at affordable price tags.

A good example of such an App is ecoVaro by Denizon.

ecoVaro not only helps businesses to monitor energy and other relevant environmental data such as Electricity, Gas, Water, Oil, Carbon, Temperature, Humidity, Solar Power, and more, but also provides analytics and comprehensive yet easy to understand reports. The data received from devices such as meters is converted into useful information that’s then presented in figures and graphs, thus allowing you to make decisions based on laid down controls.

The focus of the app is to instantly alert service engineers to go on site to fix issues.

With ecoVaro, field service engineers no longer have to return to the office to get new instructions. Also, customers don’t have to manually fire alerts to the service provider whenever something isn’t working correctly. By employing the latest in IoT, ecoVaro sends notifications to field service managers and engineers about respective customers that need support.

How ecoVaro Helps

Best-in-class companies aren’t ready to compromise on customer satisfaction. Therefore, every available avenue is used to address customer concerns with the deserved agility. By using IoT, ecoVaro makes it possible for field service providers to foresee and foreclose any possible breakdowns.

The inter-connectivity among the devices and the central communications centre results in increased revenue and improved interactivity between the system and the field engineers. This results in greater efficiency and lower downtime, which translates into improved productivity, accountability, and customer satisfaction, as well as creating a platform for a possible expansion of your customer base.

ecoVaro isn’t just about failed machines and fixes. It also provides diagnostics about connected systems and devices. With this, the diagnostics centre receives system reports in a timely manner, allowing for ease of planning and despatch of field officers where necessary.

Clearly, but using the right application, IoT can transform your business into an excellently performing field service company.