How COBIT helps you achieve SOX Compliance

First released way back in 1996, COBIT has already been around for quite a while. One reason why it never took off was because companies were never compelled to use it ? until now. Today, many CEOs and CIOs are finding it to be a vital tool for achieving SOX compliance in IT.

Thanks to SOX, COBIT (Control Objectives for Information and related Technology) is now one of the most widely accepted source of guidance among companies who have IT integrated with their accounting/financial systems. It has also gained general acceptability with third parties and regulators. But how did this happen?

Role of control frameworks in SOX compliance

You see, the Sarbanes-Oxley Act, despite having clearly manifested the urgency of establishing effective internal controls, does not provide a road map for you to follow nor does it specify a yardstick to help you determine whether an acceptable mileage in the right direction has already been achieved.

In other words, if you were a CIO and you wanted to find guidance on what steps you had to take to achieve compliance, you wouldn’t be able to find the answers in the legislation itself.

That can be a big problem. Two of your main SOX compliance obligations as a CEO or CIO is to assume responsibility in establishing internal controls over financial reporting and to certify their effectiveness. After that, the external auditors are supposed to attest to your assertions. Obviously, there has to be a well-defined basis before you can make such assertions and auditors can attest to anything.

In the language of auditors, this ?well-defined basis? is known as a control framework. Simply put, once you certify the presence of adequate internal controls in your organisation, the external auditor will ask, ?What control framework did you use??

Knowing what control framework you employed will help external auditors determine how to proceed with their evaluations and tests. For your part, a control framework can serve as a guide to help you work towards specific objectives for achieving compliance. Both of you can use it as a common reference point before drawing any conclusions regarding your controls.

But there are many control frameworks out there. What should you use?

How SOX, COSO, and COBIT fit together

Fortunately, despite SOX?s silence regarding control frameworks, you aren’t left entirely to your own devices. You could actually take a hint from the SEC and PCAOB, two of the lead organisations responsible for implementing SOX. SEC and PCAOB point to the adoption of any widely accepted control framework.

In this regard, they both highly endorse COSO, a well-established internal control framework formulated by the Committee of Sponsoring Organisations of the Treadway Commission (COSO). Now, I must tell you, if you’re looking specifically for instructions pertaining to IT controls, you won’t find those in COSO either.

Although COSO is the most established control framework for enterprise governance and risk management you’ll ever find (and in fact, it’s what we recommend for your general accounting processes), it lacks many IT-related details. What is therefore needed for your IT processes is a framework that, in addition to being highly aligned with COSO, also provides more detailed considerations for IT.

This is where COBIT fits the bill.

How COBIT can contribute to your regulatory compliance endeavors

COBIT builds upon and adheres with COSO while providing a finer grain of detail focused on IT. You can even find a mapping between COBIT IT processes and COSO components within the COBIT document itself.

Designed with regulatory compliance in mind, COBIT lays down a clear path for developing policies and good practice for IT control, thus enabling you to bridge the gap between control requirements, technical issues, and business risks.

Some of the components you’ll find in COBIT include:

IT control objectives

These are statements defining specific desired results that, as a whole, characterise a well-managed IT process. They come in two forms for each COBIT-defined IT process: a high-level control objective and a number of detailed control objectives. These objectives will enable you to have a sense of direction by telling you exactly what you need to aim for.

Maturity models

These are used as benchmarks that give you a relative measurement stating where your level of management or control over an IT process or high-level control objective stands. It serves as a basis for setting as-is and to-be positions and enables support for gap analysis, which determines what needs to be done to achieve a chosen level. Basically, if a control objective points you to a direction, then its corresponding maturity model tells you how far in that direction you’ve gone.

RACI charts

These charts tell you who (e.g. CEO, CFO, Head of Operations, Head of IT Administration) should be Responsible, Accountable, Consulted, and Informed for each activity.

Goals and Metrics

These are sets of goals along with the corresponding metrics that allow you to measure against those goals. Goals and metrics are defined in three levels: IT goals and metrics, which define what business expects from IT; process goals and metrics, which define what the IT process should deliver to support It’s objectives; and activity goals and metrics, which measure how well the process is performing.

In addition to those, you’ll also find mappings of each process to the information criteria involved, IT resources that need to be leveraged, and the governance focus areas that are affected.

Everything is presented in a logical and manageable structure, so that you can easily draw connections between IT processes and business goals, which will in turn help you decide what appropriate governance and control is needed. Ultimately, COBIT can equip you with the right tools to maintain a cost-benefit balance as you work towards achieving SOX compliance.

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Energy Cooperation Mechanisms in the EU

While the original mission of the European Union was to bring countries together to prevent future wars, this has spun out into a variety of other cooperative mechanisms its founders may never have dreamed of. Take energy for example, where the European Energy Directive puts energy cooperation mechanisms in place to help member states achieve the collective goal.

This inter-connectivity is essential because countries have different opportunities. For example, some may easily meet their renewable targets with an abundance of suitable rivers, while others may have a more regular supply of sunshine. To capitalise on these opportunities the EU created an internal energy market to make it easier for countries to work together and achieve their goals in cost-effective ways. The three major mechanisms are

  • Joint Projects
  • Statistical Transfers
  • Joint Support Schemes

Joint Projects

The simplest form is where two member states co-fund a power generation, heating or cooling scheme and share the benefits. This could be anything from a hydro project on their common border to co-developing bio-fuel technology. They do not necessarily share the benefits, but they do share the renewable energy credits that flow from it.

An EU country may also enter into a joint project with a non-EU nation, and claim a portion of the credit, provided the project generates electricity and this physically flows into the union.

Statistical Transfers

A statistical transfer occurs when one member state has an abundance of renewable energy opportunities such that it can readily meet its targets, and has surplus credits it wishes to exchange for cash. It ?sells? these through the EU accounting system to a country willing to pay for the assistance.

This aspect of the cooperative mechanism provides an incentive for member states to exceed their targets. It also controls costs, because the receiver has the opportunity to avoid more expensive capital outlays.

Joint Support Schemes

In the case of joint support schemes, two or more member countries combine efforts to encourage renewable energy / heating / cooling systems in their respective territories. This concept is not yet fully explored. It might for example include common feed-in tariffs / premiums or common certificate trading and quota systems.

Conclusion

A common thread runs through these three cooperative mechanisms and there are close interlinks. The question in ecoVaro?s mind is the extent to which the system will evolve from statistical support systems, towards full open engagement.

IT Transformation Defined

Businesses depend on IT to effectively manage business processes and to provide products and services to clients. As IT technologies advance, it is crucial that businesses update their hardware to remain competitive. But businesses should do more than simply upgrade their servers and should really strive to effect IT transformation.

What is IT Transformation?

IT transformation is the ongoing process of changing the way that a company uses IT to better align it with current business goals. Through the IT transformation process, businesses try to determine whether they are meeting mission-critical benchmarks through the incorporation of new IT technologies for corporate transformation.

For example, if one of the current business concerns is whether the company can improve customer service, the IT system will need to evolve in such a way that improves customer service in a measurable way.

Successfully Aligning the Technology to Business Goals

In order to successfully align the IT system with business goals, it is important to understand the newly integrated technologies to understand how they can change business processes. If a new feature is intended to make the server more secure, the management should know exactly how the feature will improve the security of the server and whether the new implementation is redundant.

Once the business objectives have been identified, IT transformation is carried out by changing both the software and hardware used by the company. An example would be the growing trend of server migration to the cloud. Cloud computing is the growing trend of making files and data accessible from anywhere. If an organisation believes that it can improve productivity through a server cloud migration, it will need a way to test this.

The IT Transformation Process

Given that IT transformation is directly related to the core business, the IT transformation process must begin by identifying which aspects of the company must be changed. Then, the company must determine?IT services that could potentially be integrated into the business in a way that will help the company achieve benchmarks. After the key decision-makers understand the IT network well enough to effectively implement it, the company must efficiently manage the transformation process. Then, after the IT has been integrated, the company must have a system in place to measure business transformation in a numerical way.

For example, when assessing customer satisfaction, one effective strategy would be to distribute customer satisfaction surveys that ask customers to rate their experiences on a scale of one to ten. The company can then measure the results of the customer satisfaction survey to determine whether the new IT implementations are accomplishing their intended goals.

If the expected benchmarks are not being met, the next step in the IT transformation process is to determine if there is a specific reason for that. Is there a way that the feature can be better integrated to achieve desired business objectives? Are there other features that can help the company better achieve its goals?

Upgrading a network can be an expensive process and it is important to identify early on which options are the most likely to benefit the company’s bottom line.

What ISO 14001 Status did for Cummins Inc.

Cummins manufactures engines and power generation products, and has been a household name almost since inception in 1919. It sells its products in over 300 countries, through approximately 6,000 dealerships employing 40,000 people. Because its product line runs off fossil fuel it is under steady pressure to display a cleaner carbon footprint.

Cummins decided to go for the big one by qualifying for ISO 14001 certification. This is a subset of a family of standards relating to managing environmental impact while complying with all applicable legislation. In this sense, it is similar to the ISO 9000 quality management system, because it focuses on how products are produced (as opposed to how those products perform). Compliance with ISO 14001 was a doubly important goal, because it is part of the European Union?s Eco Management and Audit Scheme and fast becoming mandatory on suppliers to governments.

The qualification process follows the well-established principle of plan, do, check, act. It begins with gap analysis to detect materials and processes that affect the environment. This is followed by implementation of necessary changes affecting operations, documentation, emergency strategies and employee education. The third step involves measuring and monitoring performance. Finally, the project moves into a phase of ongoing maintenance, and continuous improvement as circumstances change.

In Cummins case, the project was almost worldwide and called for environmental, health and safety reporting throughout the organisation. The information was shared via a globally accessible document repository, and then processed centrally at the head office in Columbia, Indiana USA.

Measuring environmental performance almost inevitably has other benefits that make it doubly worthwhile. Speaking at the 2014 National Safety Council Congress after receiving the top award for excellence, Cummins chairman and ceo Tom Linebarger commented on a journey that was ?nothing short of amazing? yet wasn’t even a ?pathway to the finish line?.

?All of us feel like we have way more to do to make sure that our environment is as safe as it could be,? he added, ?so that our sustainability footprint is as good as it can be and that we continue to set more aggressive goals every year. That’s just how we think about it.? Linebarger concluded.

If you are taking your company on a journey to new heights of environmental excellence, then you should consider choosing ecoVaro as your travelling companion. We are environmental management specialists and have proprietary software geared to process your data. We also have a wealth of experience, and a treasure chest of roadmaps to help you achieve your goal.

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