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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Can you do away with the Project Initiation Meeting?

Project initiation meetings are often skipped to fast-track projects. Once a sponsor is found, organisations go straight to project planning and execution. But based on our own experience, holding a project initiation meeting can actually eliminate many issues that may crop up in the future and hence may speed things up instead in the long run.

It is in the project initiation meeting where your project objectives and scope are clarified and all stakeholders are brought to the same page. Project sponsors and stakeholders will have to know in a nutshell what is needed from them, what the possible risks are, what different resources are required, and so on. So that, when it’s time to proceed to the next phase, everyone is already in-sync.

So what are taken up in such a meeting? Perhaps an actual example can help. Sometime in the past, we set out to work on an eCommerce website project. After conducting the project initiation meeting, these were some of the things we were able to accomplish:

  • Identified deliverables e.g. site design, interface to payment system, etc.
  • Come up with the project phases
  • Agreed what should be in and out of scope
  • Defined the acceptance test criteria
  • Identified possible risks
  • Identified the possible training and documentation work needed
  • Established whether any analysis was required, e.g. as with regards to payment interfaces
  • Formulated disaster recovery plans
  • Defined roles and responsibilities
  • Drafted timelines and due dates

Aren’t these covered in project planning? If the project is a big one, the answer is no. In a large project, project planning is a much more exhaustive activity. In a project initiation meeting, only the basic framework is defined.

Some questions may still remain unanswered after a project initiation meeting, but at least you already know what answers you need to look for. In the example we gave earlier, we left the meeting knowing that we needed:

  • a list of all necessary hardware to estimate the costs
  • to identify possible dependencies we might have with third parties
  • to identify what software had to be bought and what skills we needed to hire

When it was time to proceed to project planning, everyone involved already knew what direction we were taking. In effect, by not skipping the project initiation meeting, we were able to avoid many potential obstacles.

Energy efficiency demystified

Energy bills are all about Energy efficiency but energy efficiency management is not all about bills. Energy efficiency means reducing carbon emissions, lowering energy costs and improving the quality of life. Energy efficiency is therefore about conservation of energy in a broader perspective; in fact energy efficiency is almost becoming a moral obligation.

Through adoption of appropriate energy efficiency measures, companies can significantly bring down the overhead costs making hundreds of dollars in savings. Energy efficiency is also synonymous with a better quality of life. Taking appropriate measures to ensure proper insulation protects your premises against extreme weather conditions leading to more productivity and an improvement in the bottom line.

Improved energy efficiency means a smaller amount of carbon emissions, less pollution and a better environment.

It is now easier than ever to visually identify where your facility is wasting energy, how much energy is being wasted while tracking the progress made in reducing energy consumption by turning that detailed, raw energy-consumption data into useful charts and figures.

Having visibility of your Energy usage gives you knowledge of what power you are consuming. This helps you change energy usage behaviours and this can have significant savings and reduction in your electricity bills. Real-time electricity consumption tracking is enough prodding for you to be on the lookout for inefficient energy consumption unit’s e.g.? Heating and cooling equipment, ducts insulation of your premises or a failure of one of these components to perform as intended. Pin-pointing the problem areas is not a walk in the park but fixing it can make your building more energy-efficient and comfortable.

A wide range of solutions are now available for charting and analysing energy consumption that helps energy managers, facilities managers, energy consultants and building-services engineers. These will not only offer advice but will enable you provide tailor made solutions for your organisation by assisting you in developing a sustainable energy strategy. Our energy monitoring software is one example.?

Big Energy Data Management

Recent times have seen the advent of cloud based services and solutions where energy data is being stored in the cloud and being accessed from anywhere, anytime through remote mobile devices. This has been made possible by web-based systems that can usually bring real-time meter-data into clear view allowing for proactive business and facility management decisions. Some web based systems may even support multi utility metering points and come in handy for businesses operating multiple sites.

Whereas all this has been made possible by increased use of smart devices/ intelligent energy devices that capture data at more regular intervals; the challenge facing businesses is how to transform the large data/big volume of data into insights and action plans that would translate into increased performance in terms of increased energy efficiency or power reliability.

A solution to this dilemma facing businesses that do not know how to process big energy data, may lie in energy management software. Energy management software?s have the capability to analyse energy consumption for, electricity, gas, water, heat, renewables and oil. They enable users to track consumption for different sources so that consumers are able to identify areas of inefficiency and where they can reduce energy consumption, Energy software also helps in analytics and reporting. The analytics and reporting features that come with energy software are usually able to:

? Generate charts and graphs ? some software?s give you an option to select from different graphs

? Do graphical comparisons e.g. generate graphs of the seasonal average for the same season and day type

? Generate reports that are highly customisable

While choosing from the wide range of software available, it is important for businesses to consider software that has the capacity to support their data volume, software that can support the frequency with which their data is captured and support the data accuracy or reliability.

Energy software alone may not make the magic happen. Businesses may need to invest in trained human resources in order to realise the best value from their big energy data. Experts in energy management would then apply human expertise to leverage the data and analyse it with proficiency to make it meaningful to one?s business.

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