How To Get Started with your IT Compliance Efforts for SOX

There’s no question about it. For many of you top executives in the corporate world, all roads leading to a brighter future have to go through SOX compliance. And because the business processes that contribute to financial reporting (the crux of the Sarbanes-Oxley Act) are now highly reliant on IT systems, it is important to focus a good part of your attention there.

It is a long and arduous path to IT compliance, so if you don’t want your company to fall by the wayside due to inefficient utilisation of resources, it is important to set out with a plan on hand. What we have here are some vital information that will guide you in putting together a sound plan for SOX compliance of your company?s IT systems.

Why focus on IT systems for SOX compliance?

We’ll get to that. But first, let’s take up the specific portions of the Sarbanes-Oxley Act that affect information technology. These portions can be found in Section 302 and Section 404 of the act.

In simplified form, Section 302 grants the SEC (Securities and Exchange Commission) authority to come up with rules requiring you, CEOs and CFOs, to certify in each annual or quarterly financial report the following:

that you have reviewed the report;
that based on your knowledge, the report does not contain anything or leave out anything that would render it misleading;
that based on your knowledge, all financial information in the report fairly represent the financial conditions of the company;
that you are responsible for establishing internal controls over financial reporting; and
that you have assessed the effectiveness of the internal controls.

Similarly, Section 404, stated in simplified form, allows the SEC to come up with rules requiring you, CEOs and CFOs, to add an internal control report to each annual financial report stating that you are responsible for establishing internal controls over financial reporting.

You are also required to assess the effectiveness of those controls and to have a public accounting firm to attest to your assessment based upon standards adopted by the Public Company Accounting Oversight Board (PCAOB).

While there is no mention of IT systems, IT systems now play a significant role in financial reporting. Practically all of the data you need for your financial reports are stored, retrieved and processed on IT systems, so you really have to include them in your SOX compliance initiatives and establish controls on them.

Now that that’s settled, your next question could very well be: How do you know what controls to install and whether those controls are already sufficient to achieve compliance?

Finding a suitable guide for IT compliance

The two bodies responsible for setting rules and standards dealing with SOX, SEC and PCAOB, point to a well-established control framework for guidance – COSO. This framework was drafted by the Committee of Sponsoring Organisations of the Treadway Commission (COSO) and is the most widely accepted control framework in the business world.

However, while COSO is a tested and proven framework, it is more suitable for general controls. What we recommend is a widely-used control framework that aligns well with COSO but also caters to the more technical features and issues that come with IT systems.

Taking into consideration those qualifiers, we recommend COBIT. COBIT features a well thought out collection of IT-related control objectives grouped into four domains: Plan and Organise (PO), Acquire and Implement (AI), Deliver and Support (DS), and Monitor and Evaluate (ME). The document also includes maturity models, performance goals and metrics, and activity goals.

A few examples of COBIt’s detailed control objectives are:

DS4.2 – IT Continuity Plans
DS4.9 – Offsite Backup Storage
DS5.4 – User Account Management
DS5.8 – Cryptographic Key Management
DS5.10 – Network Security
DS5.11 – Exchange of Sensitive Data

By those titles alone, you can see that the framework is specifically designed for IT. But the document is quite extensive and, chances are, you won’t need all of the items detailed there. Furthermore, don’t expect COBIT to specify a control solution controls for every control objective. For example, throughout the control objective DS4 (Ensure Continuous Service), you won’t find any mention of virtualisation, which is common in any modern business continuity solution.

Basically, COBIT will tell you what you need to attain in order to achieve effective governance, management and control, but you’ll have to pick the solution best suited to reach that level of attainment.

Articles highly relevant to the one you just read:

Month End Accounting The Way It Should Be Today
Spreadsheet Woes ? Burden in SOX Compliance and Other Regulations
Spreadsheet Woes ? Limited Features For Easy Adoption of a Control Framework
How Internal Auditors Can Win The War Against Spreadsheet Fraud

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How Armstrong World Industries is going Cradle-to-Cradle

The Cradle-to-Cradle concept holds that human effort must be biometric, in other words enrich the environment within which it functions as opposed to breaking it down. This means manufacturing must be holistic in the sense that everything is reusable and nothing is destroyed. Armstrong World Industries was the first global mineral ceiling tile manufacturer to achieve Cradle-to-Cradle certification. We decided to take a closer look at how they achieved this.

Armstrong Worldwide Industries has five plants in the UK alone. These produce an annual turnover of ?2.7 billion. They have been making ceilings for more than 150 years. Fifteen years ago and way ahead of the curve it started recycling, and has maintained a policy of not charging contractors for waste ever since. Along the way, it developed a product that can be re-used indefinitely.

The Challenge

Going green must also be commercially sustainable. In Armstrong?s case, it faced a rise in landfill tax from ?8 per tonne per year to ?80 per tonne per year. This turned the financial cost of waste from a nuisance to a threat. It calculated that recycling one tonne of ceiling materials would:

Eliminate 456kg of CO2 equivalents by saving 1,390 kWh of electricity
Preserve 11 tons of virgin material and save 1,892 gallons of potable water

They hoped to extend their own recycling project by asking demolition and strip-out contractors to join it, so they could reprocess their scrap as new batches of tiles too.

The Achievement

As things stand today, an Armstrong ceiling tile now contains an average of 82% recycled content. Indeed, if they could find more ceilings to recycle this could reach 100%. In the past two years alone, Armstrong Worldwide Industries UK has saved 130,399m? of greenfield from landfill, being the equivalent of 520 skips that would otherwise have cost contractors over ?88,000 to dispose of.

The Broader Context

Armstrong Worldwide Industries is a global leader in water management, and is bent on minimising its reliance on fossil for energy. It has implemented online measurement systems that feed data to its corporate environmental, health and safety system. This empowers it to produce reports, track corrective actions and measure progress towards its overall goal of being carbon neutral.

Next time you sit beneath an Armstrong Worldwide Industries panelled ceiling, spare a thought for how much ecoVaro consumption analytics could contribute to your bottom line (and how it would feel to be lighter on carbon too).

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Excel Spreadsheet Conversion to SQL Reports

Spreadsheets are flexible, inexpensive and easy to use. They are especially handy when it comes to beating report submission deadlines or making impromptu data computations.

Unfortunately, organisations heavy reliance on spreadsheets have made these User Developed Applications (UDA) into high-risk office tools. Simple spreadsheet errors like leaving out a negative sign or a cut-and-paste mistake have already caused million-dollar discrepancies. Also, when a fraudulent employee enters into the picture, the risks become unimaginable.
Think TransAlta’s spreadsheet cut-and-paste glitch (the company later called this a ‘simple clerical error’) which caused the energy firm a whopping $24 million loss or Fidelity’s overstatement of its earnings owing to the omission of the minus sign on the spreadsheet of a $1.3 billion net capital loss.

Denizon can convert your Excel Spreadsheets to a web based SQL Server Reporting Services (SSRS). It does not import Excel data, rather it allows the creation and deployment of reports in a more efficient manner by querying the data.

So what is the problem with Spreadsheets?

Plagued with risk issues and vulnerable to fraud
Lacking in control features especially when copied, edited and emailed between many users
A burden to regulation compliance e.g. SOX (Sarbanes-Oxley)

Moreover:

Accidental copy-paste/Omission of a negative sign/Erroneous range selection
Incorrect data input or unintentional deletion of a character, cell, range, column, or row
Possibility of the user working on the wrong version
Prone to inconsistent company-wide reporting
Often ‘defenceless’ against unauthorised access

See Top 10 Disadvantages of Spreadsheets

What makes SQL Server Reporting Services better than Spreadsheets?

Free from spreadsheet risks & equipped with built-in controls that substantially reduce risks to data
Less prone to fraud
More suitable for regulatory compliance e.g. SOX
Designed for an agile business environment

Automatic consolidation eliminates errors and wasted time caused by tedious copy-pasting of data and linking of cells
Better collaboration capabilities allows team members to bring their heads together for planning, budgeting, and reporting even while on the go
Mobility support enables users to input data or retrieve information through their wireless mobile device

Superior sharing features ensures that everyone is exactly on the same page and viewing real-time information
Dashboards provide insightful information at-a-glance through KPIs, graphs, and various metrics
Drill-downs enable users to investigate unusual figures and gain a better understanding of the details that contribute to the big picture
Easy to learn interfaces allow your organisation to cope with fast personnel turnaround or Mergers & Acquisitions

Don’t know how to shift from Spreadsheets to SQL Server Reporting Services?

We’ve got the knowledge and expertise to assist you in:

Making a smooth and cost-efficient transition from risky spreadsheets to reliable reports
Designing and implementing SOX-compliant report-generating methods and procedures
Putting exposure to high-risk reporting methods a thing of the past

Which KPI?s to Use in CRM

Customer relationship management emerged in the 1980?s in the form of database marketing. In those tranquil pre-social media days, the possibility of ?managing? clients may have been a possibility although Twitter and Facebook took care of that. Modern managers face a more dynamic environment. If you are one, then what are the trends you should be monitoring yourself (as opposed to leaving it to others).

If you want to drip feed plants, you have to keep the flow of liquid regular. The same applies to drip-feed marketing. Customers are fickle dare we say forgetful. Denizon recommends you monitor each department in terms of Relationship Freshness. When were the people on your list last contacted, and what ensued from this?

Next up comes the Quality of Engagements that follow from these efforts. How often do your leads respond at all, and how many interfaces does it take to coax them into a decision? You need to relate this to response blocks and unsubscribes. After a while you will recognise the tipping point where it is pointless to continue.

Response Times relate closely to this. If your marketing people are hot then they should get a fast response to sales calls, email shots and live chats. It is essential to get back to the lead again as soon as possible. You are not the only company your customers are speaking too. Fortune belongs to the fast and fearless.

The purpose of marketing is to achieve Conversions, not generate data for the sake of it. You are paying for these interactions and should be getting more than page views. You need to drill down by department on this one too. If one team is outperforming another consider investing in interactive training.

Finally Funnel Drop-Off Rate. Funnel analysis identifies the points at which fish fall off the hook and seeks to understand why this is happening. If people click your links, make enquiries and then drift away, you have a different set of issues as opposed to if they do not respond at all.

You should be able to pull most of this information off your CRM system if it is half-decent, although you may need to trigger a few options and re orientate reporting by your people in the field. When you have your big data lined up speak to us. We have a range of data analysts brimming over with fresh ideas.