Spreadsheet Woes – Burden in SOX Compliance and Other Regulations

End User Computing (EUC) or end User Developed Application (UDA) systems like spreadsheets used to be ideal ad-hoc solutions for data processing and financial reporting. But those days are long gone.

Today, due to regulations like the:

  • Sarbanes-Oxley (SOX) Act,
  • Dodd-Frank Act,
  • IFRS (International Financial Reporting Standards),
  • E.U. Data Protection Directive,
  • Basel II,
  • NAIC Model Audit Rules,
  • FAS 157,
  • yes, there?s more ? and counting

a company can be bogged down when it tries to comply with such regulations while maintaining spreadsheet-reliant financial and information systems.

In an age where regulatory compliance have become part of the norm, companies need to enforce more stringent control measures like version control, access control, testing, reconciliation, and many others, in order to pass audits and to ensure that their spreadsheets are giving them only accurate and reliable information.

Now, the problem is, these control measures aren’t exactly tailor-made for a spreadsheet environment. While yes, it is possible to set up a spreadsheet and EUC control environment that utilises best practices, this is a potentially expensive, laborious, and time-consuming exercise, and even then, the system will still not be as foolproof or efficient as the regulations call for.

Testing and reconciliation alone can cost a significant amount of time and money to be effective:

  1. It requires multiple testers who need to test spreadsheets down to the cell level.
  2. Testers will have to deal with terribly disorganized and complicated spreadsheet systems that typically involve single cells being fed information by other cells in other sheets, which in turn may be found in other workbooks, or in another folder.
  3. Each month, an organisation may have new spreadsheets with new links, new macros, new formulas, new locations, and hence new objects to test.
  4. Spreadsheets rarely come with any kind of supporting documentation and version control, further hampering the verification process.
  5. Because Windows won’t allow you to open two Excel files with the same name simultaneously and because a succession of monthly-revised spreadsheets separated by mere folders but still bearing the same name is common in spreadsheet systems, it would be difficult to compare one spreadsheet with any of its older versions.

But testing and reconciliation are just two of the many activities that make regulatory compliance terribly tedious for a spreadsheet-reliant organisation. Therefore, the sheer intricacy of spreadsheet systems make examining and maintaining them next to impossible.

On the other hand, you can’t afford not to take these regulations seriously. Non-compliance with regulatory mandates can have dire consequences, not the least of which is the loss of investor confidence. And when investors start to doubt the management’s capability, customers will start to walk away too. Now that is a loss your competitors will only be too happy to gain.

Learn more about our server application solutions and discover a better way to comply with regulations.

More Spreadsheet Blogs


Spreadsheet Risks in Banks


Top 10 Disadvantages of Spreadsheets


Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry


How Internal Auditors can win the War against Spreadsheet Fraud


Spreadsheet Reporting – No Room in your company in an age of Business Intelligence


Still looking for a Way to Consolidate Excel Spreadsheets?


Disadvantages of Spreadsheets


Spreadsheet woes – ill equipped for an Agile Business Environment


Spreadsheet Fraud


Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


Server Application Solutions – Don’t let Spreadsheets hold your Business back


Why Spreadsheets can send the pillars of Solvency II crashing down

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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.

Strategy and Portfolio Management

 

A well planned strategy is the necessary bridge between brilliant leadership and excellent execution. Without it, your entire organisation cannot hope to respond quickly and effectively to challenges and changes within the landscape on which it operates.

Strategic planning involves identifying objectives, understanding what resources are needed to attain them, and then allocating the resources to the appropriate units to ensure they are used optimally towards the achievement of desired objectives. Among the end results which can be reflected by your team members are:

  1. Deeper understanding of the competitive environment;
  2. Snappy execution of plans;
  3. Faster, more aligned actions; and
  4. More intelligent and apt responses against strategic moves of the competition.

We understand the need to institute strategic management in such a way that your organisation can easily adapt to unforeseen developments. As such, all our solutions are formulated to make your organisation not only well-guided but also as dynamic as possible.

Strategy Formulation

Before you can proceed to map out any strategy for your company, you’ll have to study your company’s current environment. This will help you determine what courses of action should be taken to be able to navigate through such environment on your way to the end goal.

If you’re not a full time strategist, such a task can either be very daunting or deceivingly easy… the former can prevent your team from getting started, while the latter can lead your team astray.

Ideally, strategy formulation should be carried out as quickly and as efficiently as possible so you can move on to implementation before the competition can react. Our methods can enable your leaders to hit the ground running each time they set out on a strategic plan.

How?

  • We can assist in accurately applying strategic tools like SWOT and Gap analysis, then help integrate the results into an effective strategic plan.
  • We’ll train your team how to carry out effective research techniques so that the information they gather will really be what we need. This is because the tools mentioned earlier can only work effectively if the inputs were picked intelligently. Of course, if you want the entire process expedited, we can also conduct the research ourselves.
  • We’ll establish best practices for top-down, bottom-up, and collaborative strategic management processes. We’ll even show you how to organise and hold meetings where team members are constantly engaged and in-sync, so action plans can be developed and relayed fast.
  • We’ll see to it that strategies for all functional departments (such as IT management, supply-chain, HR, marketing, and legal) are in line with your business strategies, which should in, turn be aligned with your overall corporate strategy.

Strategy Evaluation

Your strategies have to be periodically assessed if you want to determine whether they are attuned to variations affecting your organisation. These changes may include new technologies, emerging competitors, new opportunities, as well as unexpected developments in the economic environment and political climate.

While no time limit is imposed for the build-up of resources vital to the attainment of a specific objective, the window of opportunity can shut on you before you can start amassing such resources. Given this possibility, it is important for your strategies to undergo evaluation processes that will determine whether you should pursue them or not.

Using only the most reliable evaluation techniques, we’ll help you establish whether:

  • Your strategies will place your company in a position that will give it competitive advantage or will erode whatever advantage the competition already has;
  • Your strategies are consistent with the landscape on which your company currently traverses;
  • They are realistic enough in relation to the resources you have on hand;
  • The associated risks have all been identified and the appropriate control measures have already been put in place;
  • The time frames for their full realisation are both realistic and acceptable.

Portfolio Management

In today’s highly competitive market, many of the more successful enterprises are driven by project-based systems.

Now, there’s always a tendency for project managers to become overenthusiastic and to come up with a number of projects that can’t be sustained by available resources. If your project-based company frequently runs out of resources, then either you just have too many projects running or too much is being allocated to a select few.

In both instances, the problem does not necessarily lie on the individual project managers themselves. Rather, what is needed is the ability to have full control over existing projects and investments.

Your leadership should be able to rank projects in terms of their impact to your organisation’s growth, positioning, and profitability. This will give you sufficient information when deciding which projects to pursue, prioritise, or shut down. These are the benefits you’ll gain from our services:

  • A vivid presentation of the big picture. Only when you can step back from all the detail and see the interplay of investments and resources will you be able to make wise decisions regarding how and where to position them.
  • The ability to distinguish between projects with the highest potentials and those that are outdated.
  • Access to expertise that will help you distribute your present IT infrastructure, human resources, financial resources, and facilities across running projects to obtain the biggest benefits for all stakeholders.

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Transformation to a process based organisation

Today’s global marketplace rewards nimble organisations that learn and reinvent themselves faster than their competition. Employees at all levels of these organisations see themselves as members of teams responsible for specific business processes, with performance measures tied to the success of the enterprise. As team members, they are “owners” of the process (or processes) to which they are assigned. They are responsible for both the day to day functioning of their process(s), and also for continuously seeking sustainable process improvements.

Transforming a traditionally designed “top down control” enterprise to a process-based organisation built around empowered teams actively engaged in business process re-engineering (BPR) has proven more difficult than many corporate leaders have expected. Poorly planned transformation efforts have resulted in both serious impacts to the bottom line, and even more serious damage to the organisation’s fabric of trust and confidence in leadership.

Tomislav Hernaus, in a publication titled “Generic Process Transformation Model: Transition to Process-based Organisation” has presented an overview of existing approaches to organisational transformation. From the sources reviewed, Heraus has synthesised a set of steps that collectively represent a framework for planning a successful organisational change effort. Key elements identified by Hernaus include:

Strategic Analysis:

The essential first step in any transformation effort must be development of a clear and practical vision of a future organisation that will be able to profitably compete under anticipated market conditions. That vision must be expected to flex and adjust as understanding of future market conditions change, but it must always be stated in terms that all organisational members can understand.

Identifying Core Business Processes:

With the strategic vision for the organisation in mind, the next step is to define the core business processes necessary for the future organisation to function. These processes may exist across the legacy organisation’s organisational structures.

Designing around Core Processes:

The next step is development of a schematic representation of the “end state” company, organised around the Core Business Processes defined in the previous step.

Transitional Organisational Forms/ Developing Support Systems:

In his transformation model, Hernaus recognises that information management systems designed for the legacy organisation may not be able to meet the needs of the process management teams in the new organisation. Interim management structures (that can function with currently available IT system outputs) may be required to allow IT professionals time to redesign the organisation’s information management system to be flexible enough to meet changing team needs.

Creating Awareness, Understanding, and Acceptance of the Process-based Organisation:

Starting immediately after the completion of the Strategic Analysis process described above, management must devote sufficient resources to assure that all organisation members, especially key managers, have a full understanding of how a process-based organisation functions. In addition, data based process management skills need to be provided to future process team members. It is not enough to schedule communication and training activities, and check them off the list as they are completed. It is critical that management set behavioural criteria for communication and training efforts that allow objective evaluation of the results of these efforts. Management must commit to continuing essential communication and training efforts until success criteria are achieved. During this effort, it may be determined that some members of the organisation are unlikely to ever accept the new roles they will be required to assume in a process-based organization. Replacement of these individuals should be seen as both an organisational necessity and a kindness to the employees affected.

Implementation of Process Teams:

After the completion of required training AND the completion of required IT system changes, process teams can be formally rolled out in a planned sequence. Providing new teams with part time support by qualified facilitators during the firsts weeks after start-up can pay valuable long term dividends.

Team Skill Development and Continuous Process Improvement:

Providing resources for on-going skill development and for providing timely and meaningful recognition of process team successes are two keys for success in a process-based organisation. Qualified individuals with responsibility for providing training and recognition must be clearly identified and provided with sufficient budgetary resources.

The Hernaus model for transformation to a process based organisation is both well thought out and clear. His paper provides an ample resource of references for further study.

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