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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Eck Industries Sheds Fresh Light

William Eck began his business in 1948 in a 650m2 garage building. The aluminium foundry prospered, and now has an 18,500m2 factory in Manitowoc, Wisconsin employing 250 people casting a variety of casings. Like high-tech industries around the globe it needs effective illumination. After it measured its carbon footprint, it realised it needed energy efficient lighting too.

When Eck Industries began its review it had around 360 high-pressure sodium lights throughout the plant. Their operating cost was substantial. After taking independent advice from an independent agency they realised they needed to replace these with more energy-efficient fluorescent lights that consume half as much energy.

The feasibility team conducted performance tests to determine the optimum solution. After selecting enclosed, gasketed and waterproof T8 fluorescents (available in G13 bipin, single pin and recessed double contacts) they collaborated with the supplier to calculate the best combination of 4 and 6 bulb fixtures.

The fittings they chose cost $60,000 plus $10,000 installation. However a $33,000 energy rebate wrote down 47% of this immediately. They achieved further energy savings by attaching motion sensors to lights over low-traffic walkways.

The retrofit was a huge success, with an 8 month payback via a direct operating saving of $55,000 a year. Over and above enhanced illumination Eck Industries slashed 674,000 kilowatt hours off its annual lighting bill. During the 20 year design life, this equates to a total 13.5 million kilowatt hours. Other quantifiable benefits include 443 tons less carbon, 2 tons less sulphur dioxide, and 1 ton less nitrogen oxide per year.

Many companies face similar opportunities but fail to capitalise on them for a number of reasons. These may include not being aware of what is available, lacking technical insight, being short of working capital and simply being too busy to focus on them.

Eck Industries got several things right. Firstly, they consulted an independent specialist; secondly they trusted their supplier to provide honest advice, and thirdly they accepted that any significant saving is worth chasing down. Other spin-offs were safer, more attractive working conditions and an opportunity to take their foot off the carbon pedal. This is an excellent example of what is possible when you try.

If you have measured your illumination cost and are concerned about it (but are unsure what the metric means within the bigger picture) then Ecovaro offers online reports comparing it with your industry average, and highlights the cost-benefits of alternative lighting. 

5 Numbers showing why the Time to Invest in eCommerce in the UK is Now

A decade or two ago, you might have already had the urge to invest in eCommerce. But astute as you are, you must have decided to wait for the right time and perhaps the right place to do it. That time has come. And the right place to do it? Try the United Kingdom.

Here’s why:

1. ?100 billion worth to the UK economy

A report conducted by US-based BCG (Boston Consulting Group) showed that Internet-based business in the UK reached ?100 billion in 2009. That translated to 7.2% of the country’s GDP that year, making it bigger than industries like construction, education, and health & social work, and even slightly bigger than agriculture, hotels & restaurants, and mining, combined. Click here to see the comparison shown as a graph.

?100 billion?is certainly huge, but?the market potential of the Internet in UK is even made more evident if you also look at the numbers based on amount spent per capita…

2. # 1 in per capita spending

According to IMRG (Interactive Media in Retail Group), “the UK’s per capita spend of ?1333 (?1108) per annum” is number one in the world. This shows that people from the United Kingdom are more willing to buy goods from the Internet than other people on the planet. And this alone should tell you why UK is the best place for e-commerce.

But while you’re still pondering whether now is really the best time to invest, bear in mind that competitors who have gone to the Internet before you are already thinking of expanding …

3. 1.5 million workers in Internet retailing by 2015

Last year (2011), the number of people employed in UK e-businesses was about 730,000. While conducting its second annual e-Jobs index in 2011, IMRG (Interactive Media in Retail Group) found out that it was largely due to a rise in employment in 63% of e-businesses. The study also showed that 60% of e-businesses were also planning to beef up their employees within a year’s time.

While other sectors are shrinking their ?workforce, businesses on the Internet are growing theirs. Were they just speculating? Perhaps not…

4. 50% of parsels during 2016 pre-Christmas peak will come from e-commerce

Last year (2011), parcels coming from e-commerce accounted for 37% of all items sent through UK couriers during the November-December stretch. That volume from e-commerce was 15% higher than the previous year. This remarkable climb, which was reported by Global Freight Solutions (GFS), shows the growing confidence of customers when it comes to buying products online.

If this rate continues, items from e-commerce will easily comprise 50% of parcels by 2016. Chances this rate will continue? Let’s go to number 5 and you be the judge.

5. 66% of all adults made online purchases in 2011

A statistical bulletin published by the ?Office for National Statistics revealed that 32 million people made online purchases in 2011. That actually comprises 66% of all adults in the UK. Significant as that may seem, what is really striking is that that figure used to be 62% in 2010. So again, this proves that the number of people who buy products and services online is steadily growing.

If you really think about it, these statistics should not be surprising. The smartphone is now practically the default mobile device of anyone who owns a mobile phone. And then of course there are laptops and tablets.

With these devices on hand, coupled with the ever growing number of WiFi hotspots and telecommunications bandwidth, gaining access to the Web has never been easier.?It can be done practically anytime, anywhere.

This makes it so easy for people to search for products, compare competing brands, and eventually make a purchase from home, the office, on the terminal, or on the train.

Related post:

Integrated e-commerce ? The right way to do extend your business online

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Risk Assessment

Risk assessment is a vital component in BC (Business Continuity) planning. Through risk assessment, your company may determine what vulnerabilities your assets possess. Not only that, you’ll also be able to quantify the loss of value of each asset against a specific threat. That way, you can rank them so that assets that are most likely to cripple your business when say a specific disaster strikes can be given top priority.

However, a poorly implemented risk assessment may also cost you unnecessary expenditures. Many risk assessors are too enthusiastic in pointing out risks that, at the end of the assessment, they tend to over-appraise even those having practically zero probability of ever occurring.

We can assure you of a realistic assessment of your assets’ risks and propose cost-effective countermeasures. These are the things we can do:

  • Identify your unsafe practices and propose the best alternatives.
  • Perform qualitative risk assessment if you want fast results and lesser interruptions on your operations.
  • Perform quantitative risk assessment if you want the most accurate depiction of your risks and the corresponding justifiable costs of each.
  • Conduct frequency and consequence analysis to identify unforeseen harmful events and determine their effects to various components of your organisation and its surroundings.

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