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 Sustainable is Suez Environment

French-based Suez Environment works in the water and waste-management environment, with specific reference to water production, treatment, & pollution disposal, and waste treatment, recycling, incineration and site desensitisation. Its more than 65,000 employees distributed worldwide have participated in flagship projects like Renault’s goal of 95% reclamation of vehicle parts, and Lyonnaise des Eaux?s saving of 12 million cubic meters of water in a single year.

Suez Environment claims to have consistently increased the recovery rate of treated waste, decreased direct and indirect greenhouse gas emissions, and made significant inroads into the production of sustainable energy on behalf of its clients. But then surely that’s Suez Environment’s business, and with over 65,000 employees we are entitled to expect this. Given that there have been persistent allegations of privatised water distribution bumping prices up to the detriment of the poor, how effective is Suez Environment at practising what it preaches back home?

GDF Suez is its largest shareholder and includes it under its environmental and societal responsibility umbrella. This makes environmental performance an overarching goal alongside management systems, health and safety, risk and procurement, and ethics. Its environmental ambitions spin out into the following strategies:

  • Understand the interactions between our activities and the environment
  • Open dialogue with stakeholders and foster partnerships with them
  • Set quantitative and qualitative targets at all levels of the organisation
  • Achieve optimum balance between financial and environmental challenges
  • Be proactive; anticipate impacts on the environment and plan for them
  • Increase employee awareness through interactive training and education
  • Be constantly innovative; share successes within the organisation
  • Monitor progress continuously and publish measured results achieved.

These goals direct the Suez Environment management team?s attention towards optimising performance in key areas like greenhouse gases, energy management, renewable energy, biodiversity, responsible water management, pollution prevention and health and safety considerations.

Among numerous other examples, its waste incineration programs convert hazardous and conventional waste into heat used to generate electricity without requiring virgin carbon products. Elsewhere, the same energy warms market-gardening tunnels and work places on winter days.

Suez Environment uses sophisticated energy management software to analyse information that’s transmitted by data logging devices online. ecoVaro provides a similar service in the cloud. ecoVaro adapts to your requirements providing fresh insights to your business.

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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 DevOps oils the Value Chain

DevOps ? a clipped compound of development and operations – is a way of working whereby software developers are in a team with project beneficiaries. A client centred approach extends the project plan to include the life cycle of the product or service, for which the software is developed.

We can then no longer speak of a software project for say Joe?s Accounting App. The software has no intrinsic value of its own. It follows that the software engineers are building an accounting app product. This is a small, crucially important distinction, because they are no longer in a silo with different business interests.

To take the analogy further, the developers are no longer contractors possibly trying to stretch out the process. They are members of Joe?s accounting company, and they are just as keen to get to market fast as Joe is to start earning income. DevOps uses this synergy to achieve the overarching business goal.

A Brief Introduction to OpsDev

You can skip this section if you already read this article. If not then you need to know that DevOps is a culture, not a working method. The three ?members? are the software developers, the beneficiaries, and a quality control mechanism. The developers break their task into smaller chunks instead of releasing the code to quality control as a single batch. As a result, the review process happens contiguously along these simplified lines.

Code QC Test ? ? ?
? Code QC Test ? ?
? ? Code QC Test ?
? ? ? Code QC Test
Colour Key Developers Quality Control Beneficiary

This is a marked improvement over the previously cumbersome method below.

Write the Code ? Test the Code ? Use the Code
? Evaluate, Schedule for Next Review ?

Working quickly and releasing smaller amounts of code means the OpsDev team learns quickly from mistakes, and should come to product release ahead of any competitor using the older, more linear method. The shared method of working releases huge resources in terms of user experience and in-line QC practices. Instead of being in a silo working on its own, development finds it has a richer brief and more support from being ?on the same side of the organisation?.

The Key Role that Application Program Interfaces Play

Application Program Interfaces, or API?s for short, are building blocks for software applications. Using proprietary software-bridges speeds this process up. A good example would be the PayPal applications that we find on so many websites today. API?s are not just for commercial sites, and they can reduce costs and improve efficiency considerably.

The following diagram courtesy of TIBCO illustrates how second-party applications integrate with PayPal architecture via an API fa?ade.

Working quickly and releasing smaller amounts of code means the OpsDev team learns quickly from mistakes, and should come to product release ahead of any competitor using the older, more linear method. The shared method of working releases huge resources in terms of user experience and in-line QC practices. Instead of being in a silo working on its own, development finds it has a richer brief and more support from being ?on the same side of the organisation?.

imgd2.jpg

The DevOps Revolution Continues ?

We close with some important insights from an interview with Jim Stoneham. He was general manager of the Yahoo Communities business unit, at the time Flickr became a part. ?Flickr was a codebase,? Jim recalls, ?that evolved to operate at high scale over 7 years – and continuing to scale while adding and refining features was no small challenge. During this transition, it was a huge advantage that there was such an integrated dev and ops team?

The ?maturity model? as engineers refer to DevOps status currently, enables developers to learn faster, and deploy upgrades ahead of their competitors. This means the client reaches and exceeds break-even sooner. DevOps lubricates the value chain so companies add value to a product faster. One reason it worked so well with Flickr, was the immense trust between Dev and Ops, and that is a lesson we should learn.

?We transformed from a team of employees to a team of owners. When you move at that speed, and are looking at the numbers and the results daily, your investment level radically changes. This just can’t happen in teams that release quarterly, and it’s difficult even with monthly cycles.? (Jim Stoneham)

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