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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Field service and improved visibility

A manager is someone who has control over a company. They are given the responsibility of overseeing what the company does and making important decisions. The manager is the most important person in the empire and needs to be in the know at all times. Not what happened a day ago but in real-time and from any place.

Information is necessary for this to happen. It needs to be concise, brief and straightforward. Ideally, access to job status, location information, customer information, notifications and location information should be on the palms of their hands.

To sum it all up, there should be fluid communication among personnel in the field. Information should be accessed easily from one place as it flows to another to maintain steady two-way communication. This is possible with automation meaning that no amount of data will be left unseen or unused because of paperwork that was never handed over or looked into, reducing the chance of misinformation or missing information to a minimum.

Ways improved visibility will help your business through Field Service

Organisations using field services will agree that improved visibility has more business benefits and the real question is what aspect needs improving rather than discussing the benefits.

Real-time visibility

Managers need to be in the know from anywhere at any time. The manager needs information about the company. The need not to be physically present to have an idea of what’s going on. They should know everything at all times, from what was planned for the day to real-time events.

All this information should be easily accessed from one central point and should contain everything about the company and other relevant information.

Extending the back office into the field

This two-way communication is virtually irreplaceable. At any time, the information should flow among technicians in the field and those in the back office. This will help to have a better idea of how to manage the workload and come up with solutions to some work-related issues.

Everyone in the team should be informed and be up to speed about real-time events. Keeping everyone updated improves visibility because they can make updates and decisions based on the kind of information they get.

No more lost paperwork

Managing paper trail can be quite a hassle for organisations. With tons of workload, there can be many delays meaning that some information might be missed or forgotten. People might also choose not to turn up for work for days on end and can affect how much info is processed. Some work can be left undone, and work not invoiced.

When organisations use field service management services, information is fed only once and everything else is done automatically. Say goodbye to lags or relying on last month?s data. Work will move faster because people will have more time to focus on important things rather than chasing an endless paper trail.

Business intelligence

Field service management technology will let you know what is being done in the field and with such an abundance of data, will make sound decisions for the business.

Every decision is hinged on cold facts. Information needs to be easily accessed and filtered into the right categories so that sound business decisions are made from the collected data.

Growing revenue

The abundance of real-time information and improved visibility can determine whether a business will grow or not. Each piece of information can show trends that are critical for any business to improve. Trends show how each sector is doing and sheds more light into specific areas that need a total overhaul. This may include improving customer service, products on retail or hiring more technicians.

Without information, a company is one step closer to going out of business. Every action should be geared to increase the revenue and this starts by making the right choices.

Visibility when working offline

Working offline is an issue that can affect visibility. Sometimes agents will need to work in areas that have little network coverage or are deep down working in tunnels or are around heavy machines and turbines. Field service solutions are built for the mobile environment and for workers who may find themselves in non-connected areas so that they can still use their device while offline. This makes sure that there is no loss of information while working in-field

Time-saving

Certainly, business is constrained to its environments and if the demand changes it should prove to be flexible enough to adjust to changes as they happen. Field service solutions operations like schedule need to update instantly. Once activities start rolling, nothing should create lags in the schedule so that operations flow seamlessly at all time.

Field workers can then make updates and document changes easily on the job site directly on their device by using responsive site menus, drastically saving time while feeding data and complete orders.

Improved customer service

It is not a clich? to say that the customer is always right. With real-time information, both field service and back-office technicians can improve customer relations and satisfaction. With a unified system of sharing information like the ERPs and CRMs, the field officer can know more about specific clients, their history and other data to know more about what should be done in current and future orders. This means that better decisions will be made for each customer.

How improved visibility benefits different parts of the organisation

Improved visibility in all areas of the business makes information more accessible. Here are some of the benefits that various sects of a business can get from improved visibility.

? The business owner
The manager owns the company and can access all information with just a single tap. A lot of data can be used to analyse the health of the venture. This includes revenue, inventory, customer surveys, employee hours, invoices and customer data.
Profitability is increased by putting more emphasis on customer satisfaction and improving the quality of end products and services.

? The service manager
The service manager can see what is going on in the field in real-time, and look into measures that can improve the productivity of staff members in various departments.
And with workflow automation, time-saving is at the maximum because there is less paperwork consequently improving scheduling and job completion rates.

? Service administrator/ dispatcher
For the team in the office, they can assign tasks faster. Scheduling is automatically done and updated in real-time. It eliminates the need for paperwork and leaves more time to be productive on other errands.

? The field technician
Improved visibility for a field worker means that they can do their best in any task. They can share or get critical information about orders and customers. This drastically improves job completion rates and customer satisfaction.

? HR
Live information can be used to track certain orders, the time it takes to complete orders, and the number of staff required in the organisation. Such data can be used in HR to reduce payroll errors and erroneous overtime costs.

? Finance
Field service management software can also benefit the finance team by automation of invoices. A work order can be tracked from start to the end and invoiced immediately to retain faster payments. Relevant data can be used to track revenue and expenditures, and costs.

Real-time visibility gives a company many solutions to manage the workload. In the end, visibility is also useful in increasing revenue and a smooth transition of information for the company.

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 CO₂to 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.

Using Pull Systems to Optimise Work Flows in Call Centres

When call centres emerged towards the end of the 20^th century, they deserved their name ?the sweatshops of the nineties?. A new brand of low-paid workers crammed into tiny cubicles to interact with consumers who were still trying to understand the system. Supervisors followed ?scientific management? principles aimed at maximising call-agent activity. When there was sudden surge in incoming calls, systems and customer care fell over.

The flow is nowadays in the opposite direction. Systems borrowed from manufacturing like Kanban, Pull, and Levelling are in place enabling a more customer-oriented approach. In this short article, our focus is on Pull Systems. We discuss what are they, and how they can make modern call centres even better for both sets of stakeholders.

Pull Systems from a Manufacturing Perspective

Manufacturing has traditionally been push-based. Sums are done, demand predicted, raw materials ordered and the machines turned on. Manufacturers send out representatives to obtain orders and push out stock. If the sums turn out wrong inventories rise, and stock holding costs increase. The consumer is on the receiving end again and the accountant is irritable all day long.

Just-in-time thinking has evolved a pull-based approach to manufacturing. This limits inventories to anticipated demand in the time it takes to manufacture more, plus a cushion as a trigger. When the cushion is gone, demand-pull spurs the factory into action. This approach brings us closer to only making what we can sell. The consumer benefits from a lower price and the accountant smiles again.

Are Pull Systems Possible in Dual Call Centres

There are many comments in the public domain regarding the practicality of using lean pull systems to regulate call centre workflow. Critics point to the practical impossibility of limiting the number of incoming callers. They believe a call centre must answer all inbound calls within a target period, or lose its clients to the competition.

In this world-view customers are often the losers. At peak times, operators can seem keen to shrug them off with canned answers. When things are quiet, they languidly explain things to keep their occupancy levels high. But this is not the end of the discussion, because modern call centres do more than just take inbound calls.

Using the Pull System Approach in Dual Call Centres

Most call centre support-desks originally focused are handling technical queries on behalf of a number of clients. When these clients? customers called in, their staff used operator?s guides to help them answer specific queries. Financial models?determined staffing levels and the number of ?man-hours? available daily. Using a manufacturing analogy, they used a push-approach to decide the amount of effort they were going to put out, and that is where they planted their standard.

Since these early 1990 days, advanced telephony on the internet has empowered call centres to provide additional remote services in any country with these networks. They have added sales and marketing to their business models, and increased their revenue through commissions. They have control over activity levels in this part of their business. They have the power to decide how many calls they are going to make, and within reason when they are going to make them.

This dichotomy of being passive regarding incoming traffic on the one hand, and having active control over outgoing calls on the other, opens up the possibility of a partly pull-based lean approach to call centre operation. In this model, a switching mechanism moves dual trained operators between call centre duties and marketing activities, as required by the volume of call centre traffic, thus making a pull system viable in dual call centres.

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