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
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Spreadsheet Woes ? Limited Features For Easy Adoption of a Control Framework
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Are Target Operating Models strategic compasses?

The short answer is they usually are, because every organisation needs a road-map of where they are going. Target operating models can be complex documents with illustrative details including project management structures, special tools, implementation procedures and management metrics. They can also be simple statements, as for example Winston Churchill?s promise that ?we shall fight them on the beaches, on the landing grounds and in the fields? which gave Britain the strategic direction it needed.

Many initiatives unfortunately fail because managers are ?too busy? to bottom on what their target operating model should say, or simply don’t believe in paperwork. As a result, promising initiatives may blunder off course or die a slow death without them really noticing. We cannot manage what we cannot measure, which is where the management metrics fit in. One of my favourite quotes is ?if you don’t know where you are going any road will get you there? which is what the Cheshire Cat said to Alice in Wonderland when she got lost.

The author blundered through life without a plan because there was no one else with his particular brand of imagination. The current business climate is different because everybody is trying to ramp up, and investors want to know exactly what is going to happen to their money and by when. Hence a target operating model can be indispensable throughout a change or product cycle.

The benefits of having a measurable operations / technology plan can produce powerfully tangible results if the organisation follows through on it. Built-in metrics with milestones are powerful tool for management, and, when they map through to the company financial plan almost irreplaceable as cash-flow forecasters.

Other benefits may include:

  • Shorter times to market and greater agility when launching new ideas
  • Reduced investor risk through a predictable process that’s readily monitored
  • A stable operating environment where there is consensus on direction
  • Greater likelihood of delivering on time and leading to repeat orders
  • A more cost-effective process, with less risk of loss of quality and money

Although it dates back a few years the Wills UK and Ireland Retail model still provides an excellent benchmark of a target operating plan that worked. The strategic goals were exceptionally clear, and they brought in a proven project manager to help them drive the program forward.

We have delivered advanced business management services to many of our clients, and believe you will find our personalised approach time-efficient and effective too.

Fine-tuning your Operations and keeping our staff Happy with FieldElite

They are the engine that drives your operations, but are you really giving you value for your money? How much time is spent by your personnel on lengthy paperwork and record-keeping, as opposed to actually providing the service to your customers? Manual tasks create bottlenecks and slow your operations, which in turn affects service delivery and customer satisfaction. You want to reach more clients and boost your brand image, growing your market share and generating more revenue. Field Service Management (FSM) software comes in optimise the operations of your mobile workforce, cut down resource wastage, and enhance your productivity as a firm, by actually enabling your field staff to get more done, thus achieving their individual goals. In fact, according to a report published by Fortune Business Insights?, the global FSM market- which stood at $2.29 billion as recently as 2018, will have expanded to $7.27 billion by 2026. What does this mean for your employees, and how do they benefit from FieldElite?

  • Skipping the paperwork with end-to-end automation

Filing reports, keeping track of equipment used, working on the Excel sheets for multiple jobs on a daily basis, all through to the routing and billing- it can be a logistical nightmare. It’s not just about the hours spent poring through documents and typing away at calculators. Manual work exposes you to the risks of human error. Missing records, inaccurate assessments of the situation on the ground due to the overwhelming data streaming in, putting the head office staff under strain- it all hampers the productivity of the company. 

Take scheduling for instance. You have different employees, and various jobs that need their attention, at different locations. It can be a plumbing company whose clients have water filters that need to be repaired, gas boilers inspected, leaking pipes fixed, and others who need new installations to be set up. Assigning your personnel to the different situations will need to take into account the type of job, and the amount of time that it will require, aspects such as the location and the crew that is closest to it. At the head office you will want to keep tabs on the jobs that are in progress, pending, complete, those on hold, and even those that have been cancelled. Running all these through traditional manual processes is enough to drive you to the edge. What’s more, tasks that slip through your fingers amidst the confusion will result in negative feedback from your customers- which you don’t want hitting your brand.

With a field service job management software like FieldELite, you get to handle it all from one dashboard. Optimise your service delivery using the accurate scheduler, that allows you to account for the location of your employees, the status of the job- from the urgent ones like emergency tasks, to the normal duties such as routine maintenance, and low-priority tasks. The field service scheduling software comes with a real-time location feature that allows you to determine the employees closest to the client’s premises who will be appropriate for the job, map out the service areas and give you a birds-eye view of all the operations on the ground, while being updated with the progress of each specific task. Less time is spent travelling to- and from the central office, and more on actually tending to your client’s needs. You can even have situations where you can assign end-of-day tasks to employees who will be passing on that route on their way home.

  • Enhanced resource utilisation that promotes personal and professional development

Skill is key across the industries- from electrical services, solar panel installation, landscaping, home remodelling, pest control, plumbing, HVAC system maintenance, to construction and property management. For the job to be done appropriately and make your clients happy, you want to assign the task to an employee who is particularly proficient at it. This tends to be glimpsed over during manual scheduling since the personnel at the head office will be swamped with so many files, and will pick the first one that comes close to fitting the job description, leading to overlapping of roles. Sure, they may get it done, having seen their colleagues do it and even helping them out when they worked together before on similar projects- but will it be up to the required standard? On the other hand, the FSM allows you to ensure that you get the right technician for the task- who will be more motivated, boosting their performance.

What about accidents? Your employees want to feel safe as they go about their mandate. Many of the field service jobs are hazardous- such as electrical repair jobs, window cleaning tasks at high rise buildings, to elevator repair jobs where a slight glitch can lead to severe ramifications. Field service management software also comes in handy here, where the head office can be notified of any emergency the moment it occurs, and arrange for the necessary action to be taken immediately. That way, your employees will not feel neglected while they are out in the field, showing them that their safety is a priority to your business- which in turn increases their morale. 

  • Readily available knowledgebase and feedback system

When the employees have been assigned a specific job, they will require certain information about it. This includes the scope of the task, history of previous repairs or maintenance that was carried out, accompanying images if needed, risk assessment, any hazards or contaminants that they will need to prepare for, to notes left by technicians who had handled it. Having to keep checking their email, or picking up documents at the office for the day’s job and walking around with them all day as they tend to one customer after another, will slow things down, and not to mention frustrate them. However, the FSM system is directly accessible by the employees via app on their phones. The information needed for each specific task will thus be at their fingertips, speeding up the process and ensuring that they will be ready for each project being handled. 

While carrying out the job itself, the employees will use the very same app to update the system on how it is progressing, chat with the staff at the head office, update the inventory and even place orders for extra parts if necessary. Since mobile service management software apps like FieldElite also work in offline mode, the photos, reports and other entries that are made are collected by the app and saved on the device. Once a network connection is established, they are then updated to the central database- thus ensuring that the job can proceed regardless of the location. 

Once the job is completed, the customer input is also taken, registered in the system through their e-signature. A signoff comment included gives the customer the opportunity to indicate their experience with the job, and the feedback that they would like to provide. In case the job has not been completed, then the scheduling software kicks in, putting it in queue for another appointment to take care of the task, or resolve the issue that had caused it not to be completed the first time. The completed tasks head right to invoicing, which is also handled within the field service management platform, making it a seamless task for the head office staff.

How Internal Auditors can win The War against Spreadsheet Fraud

To prevent another round of million dollar scandals due to fraudulent manipulations on spreadsheets, regulatory bodies have launched major offensives against these well-loved User Developed Applications (UDAs). Naturally, internal auditors are front and center in carrying out these offensives.

While regulations like the Sarbanes-Oxley Act, Dodd-Frank Act, and Solvency II can only be effective if end users are able to carry out the activities and practices required of them, auditors need to ascertain that they have. Sad to say, when it comes to spreadsheets, that is easier said than done.

Because spreadsheets are loosely distributed by nature, internal auditors always find it hard to: locate them, identify ownership, and trace their relationships with other spreadsheets. Now, we’re still talking about naturally occurring spreadsheets. How much more with files that have been deliberately tampered?

Spreadsheets can be altered in a variety of ways, especially if the purpose is to conceal fraudulent activities. Fraudsters can, for instance:

  • hide columns or rows,
  • perform conditional formatting, which changes the appearance of cells depending on certain values
  • replace cell entries with false values either through direct input or by linking to other spreadsheet sources
  • apply small, incremental changes in multiple cells or even spreadsheets to avoid detection
  • design macros and user defined functions to carry out fraudulent manipulations automatically

Recognising the seemingly insurmountable task ahead, the Institute of Internal Auditors released a guide designed specifically for the task of auditing user-developed applications, which of course includes spreadsheets.

But is this really the weapon internal auditors should be wielding in their quest to bring down spreadsheet fraud? Our answer is no. In fact, we believe no such weapon has to be wielded at all?because the only way to get rid of spreadsheet fraud is to eliminate spreadsheets once and for all.

Imagine how easy it would be for internal auditors to conduct their audits if data were kept in a centralised server instead of being scattered throughout the organisation in end-user hard drives.

And that’s not all. Because a server-based solution can be configured to have its own built-in controls, all your data will be under lock and key; unlike spreadsheet-based systems wherein storing a spreadsheet file inside a password-protected workstation does not guarantee equal security for all the other spreadsheets scattered throughout your company.

Learn more about Denizon’s server application solutions and discover a more efficient way for your internal auditors to carry out their jobs.

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