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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Understanding Carbon Emissions

Carbon emission is one of the hottest issues in the world of energy and environment today. While it is supposedly an essential component of the ecosystem, it has already become a large contributing factor to climate change. Carbon emission might be good but abuse of this natural process has made it harmful to people across the globe.

This series of articles aims to help people understand the intricacies of carbon emission and what society can do to efficiently manage this natural occurrence.

Natural Carbon Cycle

Two important elements in the carbon cycle are carbon, which is present in every living thing all over the world; and oxygen, which is found in the air that people breathe. When these two bond together, they create a colourless and odourless greenhouse gas known as carbon dioxide, which is then crucial to trapping infrared radiation heat in the atmosphere and also for weathering rocks.

Carbon is not only found in the atmosphere of the earth. It is also an element found in oceans, plants, coal deposits, oil and natural gas from deep down the earth?s core. Through the carbon cycle, carbon moves naturally from one portion of the earth to another. Looking at this scenario, one can see that the natural carbon cycle is a healthy way to release carbon dioxide into the air in order to be absorbed again by trees and plants.

Altered Carbon Cycle

The natural circulation of carbon among the atmosphere is vital to humankind. However, studies show that humans misuse this natural cycle and abuse it instead. Whenever people burn fossil fuels such as coal, oil and natural gas, they produce carbon dioxide ? which is an excess addition to the natural flow of carbon in the environment. The problem is that the release of carbon dioxide is much more than what plants and trees can re-absorb. People are not only adding CO2 to the atmosphere, they are also influencing the ability of natural sinks, such as forests, to remove it from the atmosphere. Humans alter the carbon cycle by contributing doubled or tripled greenhouse gas to the atmosphere, faster than nature can ever eliminate. Worst, nature?s balance is destroyed.

The Result

Greenhouse gases include carbon dioxide, methane, nitrous oxide, fluorinated gas and other gases. Although these gasses contribute to climate change, carbon dioxide is the largest greenhouse gas that humans emit. The reason why people talk about carbon emissions most, is because we produce more carbon dioxide than any other greenhouse gas.

The increasing amount of carbon emissions cause global warming to become more evident. All the extra carbon dioxide causes the earth?s overall temperature to rise as well. As the temperature increases, climate also changes unpredictably. Flood, droughts, heat waves and hurricanes are now widely experienced even in places where these phenomenon never used to happen.

To be able to reduce the risk of more severe weather conditions means burning less fossil fuels and shifting more to renewable sources. This is never easy. But, definitely, it’s worth a try.

How FieldElite helps Plumbers

While most people think that running a plumbing business is a very easy job, things are a bit different on the ground. The job goes beyond the dropping by a client’s home and fixing a few pipes. In addition to the actual plumbing work, a plumbing business also involves managing quotes, invoicing customers, dispatching field service workers, and accounting, among others. Undertaking all these operations manually is extremely demanding. Besides the tedious work that it is, you’re likely to end up with a ton of errors. 

However, you can overcome these challenges by employing technology. The use of field service management software allows you to automate tasks. Consequently, you no longer have to deal with paperwork, delayed responses to customer requests, or double assignment of tasks.

If you’re wondering which field service management software to use, FieldElite is your best bet. FieldElite is feature-rich, and it gives you way more than the simple automation of the daily operations of your plumbing business.  

Below are some of the top benefits you’ll reap by using FieldElite to run your plumbing venture.  

Convenient Scheduling

Scheduling is an important aspect of the plumbing industry. Just like other field techs, plumbers would require tasks to be dispatched on time, which is only made possible by proper scheduling. With FieldElite, managers can easily schedule single and recurring tasks for the right plumber in a matter of seconds. 

On the other hand, plumbers can also view the available jobs and job information in the FieldElite easy to use App that’s available for Android, and confirm scheduled jobs. They can also accept these jobs using their smartphones and respond to service requests instantly.

Apart from getting the scheduled tasks, the FieldElite scheduling and dispatch feature is integrated with GPS functionality so that plumbers can get information on where to go next, and the optimal route to take from their mobile phones. 

The scheduling and dispatch feature also gives plumbers the information on the specific tools required for the job to allow them to get the tools in between appointments and schedules. 

Central Data Storage

Just like other field service industries, plumbing also involves big data. Handling data manually would mean more errors for your plumbing business, which will only impact negatively on your business. To eliminate such errors, go paperless with FieldElite. 

You can view everything from one place with FieldElite?s dashboard feature, including information about your plumbers and the scheduled tasks. On the other hand, your plumbers can access job details and the pending tasks from a central place. 

Plumbers can also get service requests from customers on the FieldElite mobile app from wherever they are. All the requests are stored in a central place, making the response to customer requests easier. The end result is satisfied customers, opening doors for return orders. 

In case of an update, all plumbers receive notifications at the same time and, where necessary, respond promptly to the requests. They can update the office instantly with job status changes from a central place. 

Convenient Reporting

Reporting is part of the tasks that plumbers have to do after completing the assigned job. As a manager, you expect your plumbers to keep you updated on the status of each assignment. Reporting on paper is time-consuming, and that’s why you need the services of FieldElite. 

With FieldElite reporting feature, sending over completed job reports is only a few clicks away. Plumbers can generate reports on the mobile app and keep the office staff updated on the status of the job. Using FieldElite, you can capture customer signatures and add attachments to the job status and send them instantly using the mobile app available on Android. 

Since they can do instant reporting via the mobile app, the plumbers can proceed to attend to new service requests as soon as they’re done without having to first come back to the office to submit their reports. 

Effective Communication

Timely communication is very essential if you’re working with field technicians. Since you’ll not always be with them in the field, it’s always important to establish a proper communication channel to ensure information reaches your plumbers in time. Here, you can get much more with FieldElite, including communication automation to remind customers of appointments.

With FieldElite field service management software, plumbers receive notifications through the mobile app. The notifications can be for anything from new task requests, requests for alterations, emergencies, and more. On the other hand, office-based staff gets to access the reports once the plumber completes their given task. 

That means the plumbers in the field and the office-based team gets communication instantly, enabling them to see and manage their workloads. For this reason, plumbers can complete multiple tasks within a short time, thus improving their overall productivity.

Scalability

The biggest question for most entrepreneurs when they want to buy management software is scalability. Businesses grow and incorporate new activities that would also require to be managed from a centralised system. Where that’s not possible, the business would have to move all their information from one system to a more robust one. 

With FieldElite, however, you’re safe. It works perfectly well for startups as well as large-sized plumbing businesses. It allows you to focus on the areas that your organisation covers now, but also lets you add new areas as you introduce them into your business. Moreover, FieldElite is also receiving regular updates to that bring it up-to-speed with new technologies and new ways of doing things, meaning that your business will be in a position to take advantage of the latest and more productive features. 

From the benefits mentioned above, it’s quite clear that your plumbing industry greatly needs the services of a field service management software. Your plumbers too need easier time working on their assigned tasks, adding to the reasons why you need to integrate FieldElite in your plumbing business.

2015 ESOS Guidelines Chapter 3 to 5 ? The ESOS Assessment

ESOS operates in tandem with the ISO 50001 (Energy Management) system that encourages continual improvement in the efficient use of energy. Any UK enterprise qualifying for ESOS that has current ISO 50001 certification on the compliance date by an approved body (and that covers the entire UK corporate group) may present this as evidence of having completed its ESOS assessment. It does however still require board-level certification, following which it must notify the Environment Agency accordingly.

The Alternate ESOS Route

In the absence of an ISO 50001 energy management certificate addressing comprehensive energy use, a qualifying UK enterprise must:

  1. Measure Total Energy Consumption in either kWh or energy spend in pounds sterling, and across the entire operation including buildings, industrial processes and transport.
  2. Identify Areas of Significant Energy Consumption that account for at least 90% of the total. The balance falls into a de minimis group that is officially too trivial to merit consideration.
  1. Consider Available Routes to Compliance. These could include ISO 500001 part-certification, display energy certificates, green deal assessments, ESOS compliant energy audits, self-audits and independent assessments
  1. Do an Internal Review to make sure that you have covered every area of significant consumption. This is an important strategic step to avoid the possibility of failing to comply completely.
  1. Appoint an Approved Lead Assessor who may be internal or external to your enterprise, but must have ESOS approval. This person confirms you have met all ESOS requirements (unless you have no de minimis exceptions).
  1. Obtain Internal Certification by one of more board-level directors. They must certify they are satisfied with the veracity of the reports. They must also confirm that the enterprise is compliant with the scheme.
  1. Notify the Environment Agency of Compliance within the deadline using the online notification system as soon as the enterprise believes is fully compliant.
  1. Assemble your ESOS Evidential Pack and back it up in a safe place. Remember, it is your responsibility to provide proof of the above. Unearthing evidence a year later it not something to look forward to.

The ESOS assessment process is largely self-regulatory, although there are checks and balances in place including lead assessor and board-level certifications. As you work through what may seem to be a nuisance remember the primary objectives. These are saving money and reducing carbon emissions. Contact ecoVaro if we can assist in any way.

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