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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ESOS ? Why we must have it

The 9,000 big UK businesses directly affected by the new Energy Saving Opportunity Scheme could save UK?250 million between them, or an average UK?27,000 each, if they reduced electricity consumption by just 1%. The total amount is equal to the output of five power stations, at a time when Britain?s grid is under strain.
On 26 November 2014, UK Energy and Climate Change Secretary Ed Davey met with over 100 opinion makers from businesses, charities and universities at the Institute of Directors. The gist of what he presented was:

  • ?Britain?s big firms are spending around ?2.8 billion extra each year on inefficient energy technologies ? the equivalent output of nearly five power stations;
  • Now is the time to seize the opportunity with ESOS ? and organisations up and down the country are already gearing up to make changes to save energy, save money and save the environment.
  • If business did what business is supposed to do [that is innovate to make money] and act and invest, it will save ? and that’s the bottom line.?

The environmental benefits are as important although EcoVaro agrees with Ed Davey for taking a pecuniary approach. Businesses above the threshold of 250 staff and a balance sheet of UK?34 million would have not achieved their status unless they spent their money wisely.
The discussion panel included Rhian Kelly (Director of Business Environment at CBI), and Paul Ekins (Director UCL Institute for Sustainable Resources & Deputy Director of the UK Energy Research Centre). Hugh Jones, Managing Director, Advisory at the Carbon Trust responded to Ed Davey?s remarks by commenting:

  • ?At the Carbon Trust we have already engaged with hundreds of businesses on ESOS, helping to explain how they can achieve compliance while also making significant energy savings and cutting carbon.
  • Businesses often aren’t aware of opportunities in energy efficiency, or they don’t realise how attractive the paybacks can be. By requiring companies to understand exactly how they can make cost-effective investment in energy efficiency, they are far more likely to take action.
  • From the interest we have seen so far we expect ESOS to benefit British business by helping companies to reduce overheads and increase competitiveness.

The UK?s Energy Saving Opportunity Scheme ESOS is a gold mine of opportunities for big business, the environment and the population that breathes the air. Measurement of critical energy throughputs is the beginning of the process. EcoVaro is standing by to help you convert your data to meaningful information.

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.

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.

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