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 Ventura Bus Lines cleaned up its Act

Melbourne?s Ventura Bus Lines grew from a single bus in 1924 to a mega 308-vehicle fleet by the start of 2014. The family-owned provider has always been community centric; when climate-change became an issue it took quick and urgent action. As a result it now stands head and shoulders above many others. Let’s take a closer look at some of its decisions that made the difference.

The Important Things to Focus On

Ethanol Buses ? Ventura is the only Australian company that uses ethanol power produced from sugar cane for experimental public transport. It compares emissions within its fleet, and knows that these produce significantly less CO2 while also creating jobs for locals.

Electric Buses ? The company has been operating electric buses since 2009. These carry 42 seated among a total 68 passengers. The ride is smooth thanks to twin battery banks kept charged by braking and forward momentum. When required, a two-litre VW engine kicks in automatically.

Ongoing Driver Training ? Ventura provides regular retraining sessions emphasising safe, environmentally-friending operations. Drivers are able to see their fuel consumption and carbon emissions online and experiment with ways to improve these.

Bus U-Turns ? The capacity to measure throughput convinced the company to abandon the principle that buses don’t do U-Turns for safety?s sake. Road re-engineering made this possible in a busy downtown street. This reduced emissions equivalent to 4,000 cars and reduced vehicle downtime for servicing.

Increased Business – These initiatives allowed Ventura Bus Lines to improve its service as customers experience it. This led to an uptake in patronage and a corresponding downturn in the number of passenger car hours. The pleasure of travelling green no doubt contributed to this.

How Measuring Made the Difference

Ventura Bus Lines is big business. Its 308 buses operate out of 5 depots, cover 31% of the metropole, and transport close to 70,000 passengers on average daily which is no minor task. The ability to track, measure and analyse carbon emissions throughout the area has earned it compliance with National Greenhouse Energy Reporting Threshold 1 legislation.

It also uses the data to re-engineer bus routes to further reduce fuel consumption, energy consumption and operating costs. It’s amazing how measuring is affecting its bottom line, and the health of the Melbourne community at large.

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Why Executives Fail & How to Avoid It

The ?Peter Principle? concerning why managers fail derives from a broader theory that anything that works under progressively more demanding circumstances will eventually reach its breaking point and fail. The Spanish philosopher Jos? Ortega y Gasset, who was decidedly anti-establishment added, “All public employees should be demoted to their immediately lower level, as they have been promoted until turning incompetent”.

The Peter Principle is an observation, not a panacea for avoiding it. In his book The Peter Principle Laurence J. Peter observes, “In a hierarchy every employee tends to rise to his level of incompetence … in time every post tends to be occupied by an employee who is incompetent to carry out its duties … Work is accomplished by those employees who have not yet reached their level of incompetence.”

Let’s find out what the drivers are behind a phenomenon that may be costing the economy grievously, what the warning signs are and how to try to avoid getting into the mess in the first place.

Drivers Supporting the Peter Principle

As early as 2009 Eva Rykrsmith made a valuable contribution in her blog 10 Reasons for Executive Failure when she observed that ?derailed executives? often find themselves facing similar problems following promotion to the next level:

The Two Precursors

  • They fail to establish effective relationships with their new peer group. This could be because the new member, the existing group, or both, are unable to adapt to the new arrangement.
  • They fail to build, and lead their own team. This could again be because they or their subordinates are unable to adapt to the new situation. There may be people in the team who thought the promotion was theirs.

The Two Outcomes

  • They are unable to adapt to the transition. They find themselves isolated from support groups that would otherwise have sustained them in their new role. Stress may cause errors of judgement and ineffective collaboration.
  • They fail to meet business objectives,?but blame their mediocre performance on critical touch points in the organization. They are unable to face reality. Either they resign, or they face constructive dismissal.

The Warning Signs of Failure

Eva Rykrsmith suggests a number of indicators that an individual is not coping with their demanding new role. Early signs may include:

  • Lagging energy and enthusiasm as if something deflated their ego
  • No clear vision to give to subordinates, a hands-off management style
  • Poor decision-making due to isolation from their teams? ideas and knowledge
  • A state akin to depression and acceptance of own mediocre performance

How to Avoid a ?Peter? in Your Organization

  • Use succession planning to identify and nurture people to fill key leadership roles in the future. Allocate them challenging projects, put them in think tanks with senior employees, find mentors for them, and provide management training early on. When their own manager is away, appoint them in an acting role. Ask for feedback from all concerned. If this is not positive, perhaps you are looking at an exceptional specialist, and not a manager, after all.
  • Consider the future, and not the past when interviewing for a senior management position. Ask about their vision for their part of the organization. How would they go about achieving it? What would the roles be of their subordinates in this? Ask yourself one very simple question; do they look like an executive, or are you thinking of rewarding loyalty.
  • How to Avoid Becoming a ?Peter??Perhaps you are considering an offer of promotion, or applying for an executive job. Becoming a ?Peter? at a senior level is an uncomfortable experience. It has cost the careers of many senior executives dearly. We all have our level of competence where we enjoy performing well. It would be pity to let blind ambition rob us of this, without asking thoughtful questions first. Executives fail when they over-reach themselves, it is not a matter of bad luck.

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What is work force management?

For organisations to ensure they provide the right service.  In order to do they need to assign the right employees with the right skills to the right job at the right time to meet demand.

Workforce Management Background

Workforce management (WFM) is a strategy used by companies to increase their efficiency and performance. It entails all activities aimed at maintaining a steady output, such as human resource management, forecasting, field service management, budgeting, scheduling, performance and training management, analytics, recruitment and data collection.

Workforce management utilizes a unique set of performance enhancing tools and software to bolster corporate management, workers, and other categories of managers and supervisors in the manufacturing team, distribution, transportation, and retail operators. This is sometimes called HRM systems, or part of ERP systems, or workforce asset management.

Unlike the conventional outlay that only needed staff scheduling to improve time management, workforce management is now all-inclusive and demand-oriented to optimize staff scheduling. Apart from focusing on demand-orientation and optimization, workforce management also incorporates:

  • Estimating the workload and resource utilisation
  • Job scheduling
  • Management of working times and accounts
  • Monitoring the process of workforce management

Each task should be clearly defined and performed efficiently based on set engineering standards and methods of optimizing each task as much as possible. Out of this framework and demand based forecasts, workers are scheduled and given tasks, performance measured, give feedback, and incentives computed and paid.

Workforce management is an entire scheme aimed at building the capacity of workers, increase productivity and client relations, and where possible reduce labour costs.

What is Mobile Workforce Management (MWM)

Mobile workforce management (MWM) is a software-based service used to oversee employees outside of the institution?s premises; MWM sometimes refers to the field teams. Mobile workforce management encompasses all activities done to monitor and schedule the field workforce.

The entire process includes procurement, management and using mobile devices, applications and computer software. Related support services like tracking, logging, dispatch, productivity management, and other types of communication are also to make it efficient.

Companies do not have the same needs and MWM firms need to fine-tune their software and devices to sufficiently bridge this gap. Some providers are suited only to a specific type of company because of specialization, like managing the electric grid. This experience makes the MWM company suited to provide applications that are relevant to the company for them to continue operating smoothly and efficiently.

With the increase in mobile devices, applications, secured wireless networks and virtual desktop, there comes a stream of opportunities for small and medium-sized businesses (SMB) and other ventures. Nevertheless, a mobile workforce needs better controls, security and support, as well as a functioning mobile workforce management strategy.

MMS (managed mobility services) is often used interchangeably with MWM, but they should not be confused. MWM is related to software and applications used by mobile and computer devices to manage on-field work while MMS focuses on enterprises, and is like a way of keeping in touch with the company, other employees, and linking the mobile while at work to servers and the database.

Benefits of Mobile Workforce Management

MWM allows the utilization of technology to drive productivity. Here are the top five advantages of MWM..

  1. Customer focused. The customer is the backbone of any business. The team needs to keep in touch with up-to-date information about every interaction. In the end, better client relation makes sure that the customer is always happy.
  2. Information has the power to build or destroy. A cloud-based system is easier to manage and can help with collection of data which is used to make business decisions. This can help cut costs, increase the workforce support, and identify areas where polishing needs to be done.
  3. Improved efficiency. Mobile workforce management is majorly used in taskforce allocation. If the company adopts a cloud-based work force management system, allocation is done automatically saving a lot of time.
  4. Increased revenue. Each business seeks to maximize the profit. With cloud-based mobile workforce management some operations like task management, data analysis, customer communication, reporting, and performance monitoring can be automated. This reduces the costs incurred for multiple applications and saves time.
  5. Ease of communication. Communication is vital. Constant communication with customers drives sales rates and everyone loves that. Quick communication will help customers solve their problems faster and get instant feedback.

Additional WFM benefits

 Other WFM benefits are:

  • Operations are made efficient as all complex processes are automated.
  • Employers learn more about worker engagement, productivity and attendance, allowing them to modify training, coaching and processes aimed at streamlining performance.
  • Automation and easy manipulation of data to improve HR, productivity and slash administrative costs.
  • It increases employee productivity by reducing absenteeism and late arrivals.
  • Boosts the morale of employees by encouraging transparency and facilitating manager-employee communication.
  • WFM analyzes market and schedule requirements to pick the right employee with the best set of skills for a certain task.

Companies which embrace workforce management and mobile workforce management have a higher operational efficiency. They have lower operational costs and limit manual work as much as possible

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