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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How Ventura Bus Lines cleaned up its Act

Melbourne?s Ventura Bus Lines grew from a single bus in 1924 to a mega 308-vehicle fleet by the start of 2014. The family-owned provider has always been community centric; when climate-change became an issue it took quick and urgent action. As a result it now stands head and shoulders above many others. Let’s take a closer look at some of its decisions that made the difference.

The Important Things to Focus On

Ethanol Buses ? Ventura is the only Australian company that uses ethanol power produced from sugar cane for experimental public transport. It compares emissions within its fleet, and knows that these produce significantly less CO2 while also creating jobs for locals.

Electric Buses ? The company has been operating electric buses since 2009. These carry 42 seated among a total 68 passengers. The ride is smooth thanks to twin battery banks kept charged by braking and forward momentum. When required, a two-litre VW engine kicks in automatically.

Ongoing Driver Training ? Ventura provides regular retraining sessions emphasising safe, environmentally-friending operations. Drivers are able to see their fuel consumption and carbon emissions online and experiment with ways to improve these.

Bus U-Turns ? The capacity to measure throughput convinced the company to abandon the principle that buses don’t do U-Turns for safety?s sake. Road re-engineering made this possible in a busy downtown street. This reduced emissions equivalent to 4,000 cars and reduced vehicle downtime for servicing.

Increased Business – These initiatives allowed Ventura Bus Lines to improve its service as customers experience it. This led to an uptake in patronage and a corresponding downturn in the number of passenger car hours. The pleasure of travelling green no doubt contributed to this.

How Measuring Made the Difference

Ventura Bus Lines is big business. Its 308 buses operate out of 5 depots, cover 31% of the metropole, and transport close to 70,000 passengers on average daily which is no minor task. The ability to track, measure and analyse carbon emissions throughout the area has earned it compliance with National Greenhouse Energy Reporting Threshold 1 legislation.

It also uses the data to re-engineer bus routes to further reduce fuel consumption, energy consumption and operating costs. It’s amazing how measuring is affecting its bottom line, and the health of the Melbourne community at large.

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Business Turnaround Tip for a Successful MBO Turned Awry

When you acquire a company through an MBO, your hopes are always high. You know the business more than anyone else and you’ve got too much at stake to do a sloppy job. So how could things go wrong? Well sometimes they do. And if you don’t make a quick business turnaround, you could end up losing more than just your company.

If that management buyout was financed by a bank, then chances are you were required to invest a sizeable amount from your own pockets. I won’t be surprised if you even remortgaged your house for it.

Regardless of your source of funding, whether it was a bank, a venture capitalist or through a deferred consideration, the mere thought of losing your job and getting buried in enormous debt at the same time might be too much to bear. If you get too overwhelmed by your emotions and can’t think clearly, you’ll have to step out of the driver?s seat and have someone take over.

That someone can’t be a member of the management team that took part in the management buyout. Like you, he/she might be in panic mode as well. You need someone from the outside who has no emotional attachments to the company and hence can view the crisis from a clear perspective.

Here’s what’s needed:

Review and Plan

Take a closer look at all factors affecting your business: governance and organisational structures, employees, suppliers, systems and procedures, roles and responsibilities, etc. Identify potential risks and assess the likelihood of them affecting your business.

This will give a clearer picture of cause-and-effect relationships as well as the specific tasks on hand.

Thus, when it is time to draft a plan, you can do so from a well-informed standpoint. This will enable you to target specific areas of improvement and avoid pointless activities.

Assure all stakeholders

Once a watertight plan has been formulated, you will have to approach your stakeholders. They?ll need to know what your directions are. Once they’re all sold on the plan, you could implement our strategies unimpeded.

This is a very crucial part because a sceptical stakeholder can serve as a major stumbling block in our efforts to improve the situation. You need to convince your banks, sponsors, and investors in order to avoid additional financial obstacles. You need to convince your suppliers too. If they cut off or limit supply, you won’t be able to continue doing business.

Most of all, you need to persuade your staff and employees that the proposed major changes have to be carried out in order for the company to survive. You can’t run your operations without them on board.

Redesign and set up new systems and procedures

Any company requiring a turnaround will certainly have systems and procedures that are no longer working well in the current conditions and hence would require either major changes in key areas or a total revamp. You need to study personnel roles and responsibilities as well as systems and processes, including financial and IT systems, and supervise the implementation of necessary changes.

You will need to evaluate your existing IT architecture and determine how you can best maximise what you already have and propose what you think will work more efficiently for our proposed systems and procedures. Every piece of hardware or software recommended will take into consideration your present resources. There are many solutions out there, you just need to find the best fit.

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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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