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
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How Energy Management Software Benefits Your Business

We’re in an era of price volatility in gas and electricity prices, coupled with greater scrutiny on the environmental impact of businesses in their day-to-day operations. According to the Department of Energy & Climate Change, the average SME can slash its energy bill by 18-25% simply by installing energy efficiency solutions in their facility.

Are you looking to improve energy use in your business? Prevent wastage, track consumption, identify opportunities to save on energy and reduce your carbon footprint while at it? It can be a daunting process to do it all manually. Taking those meter readings, preparing spreadsheets and combing through quotes and energy bills to validate them – this is not something you should be enduring in this day and age. Not when there are dedicated systems built for the task. That’s where Energy Management Software (EMS) comes in.

Importance Of Energy Management Software

Wasted energy = Wasted money

Failing to improve energy efficiency is costing SMEs loads of funds, with it coming to between £5,801 and £12,109 of missed annual savings for individual businesses. These are 18% – 24% of their energy costs. Where do you stand?

Take timers and thermostats for instance. When not properly set and controlled, or even simply forgetting to turn them down when not in the room, it can easily lead to unnecessary costs. How often do your staff forget to turn off the air conditioning when they leave the meeting rooms? Do you account for weekends or bank holidays when setting the controls of the AC? Mistakes like turning the temperature high on the thermostat to “quickly warm the room” are common, yet heating costs go up by about 8% with every 1°C rise.

There are installations that you can make to minimize wastage. For example, the Chinese Contemporary Arts Centre in Manchester is able to save £4,363 annually just by having a £100 timer installed to its heating system.

Some energy saving measures won’t even cost you a penny. For instance, did you know that you can save up to 30% of your heating costs simply by preventing cold air from entering the building? This means not keeping the doors just open for convenience. So how can you find points of weakness and areas of improvements in your facility? Install an EMS.

While businesses vary from one industry to the next, energy management basically boils down to:

Metering systems where the consumption is recorded
Determining how much energy can be saved by identifying opportunities for this
Implementing policies and changing existing systems to take advantage of these opportunities
Tracking progress after the improvements have been made

Benefits Of EMS For Your Business

Data Acquisition – Where accuracy and reliability matters

Energy data comes from different angles and formats. From the building automation systems and IoT devices that have been set up, bills sent in by the utility company to the spreadsheets needed to analyse them – what if you had it all from one point of reference? The EMS gives you a “bird’s eye view” of all your energy data from one interface. It collects the data from any system – and being cloud-based, is accessible from anywhere in the world.

The ecoVaro data loggers can be connected with the Wi-Fi network of the facility or function independently, depending on your specific requirements. They monitor readings 24/7, retaining the data even when they have been powered off. The end-to-end encryption assures you of the security of the information that is being obtained.

Integrating the EMS into the existing systems will simplify the data collection process, and even for the cases where there isn’t a direct method transferring the data into the system, the setup wizards that come with the EMS allow you to prepare the required data and import it.

Data Analysis: From consumption, energy leaks to areas of improvement

The first step is accurately collecting the data. The next step is making sense of it. The analysis modules with the EMS allow you to monitor the energy consumption of the facility in real-time.

The energy data is displayed in engaging graphics that are easy to understand at a glance. The dashboard setup, with its customised layout, enables you to monitor the performance of the specific information you want, toggling through usage and savings data, to the meters and sites that are being tracked. With the ecoVaro Energy Management Software, you get Consumption Charts, Regression Charts, Cusum Charts and Heatmaps right to the submeter level. This information can be broken down into 15-minute durations, with the daily, weekly and monthly consumption reports.

Getting everyone on board

Making changes to company-wide energy policies needs to have the different parties on board – from the energy manager in charge of crunching the numbers and presenting the information, the CFO of the business, the staff running day-to-day operations, all through to plant operators for those in industries. An easy mode of communication is needed, that will be understood and availed in reports that can be shared with the relevant parties in the organization. The graphical displays that come with the EMS enable actionable information to be displayed in a simplified manner – that way all members of the business or organization will be able to comprehend it.

Meet your Energy Goals

The baseline that is created in the EMS is used as a standard when assessing the impact of future changes to the energy consumption. Using the information that has been obtained, the management can set up energy saving policies and implement changes, and track KPIs (key performance indicators) along the way. For instance, the market research company DJS Research installed a timer switch that turns off their two water coolers when they aren’t in use. This action saves them £144 annually, and had already paid for itself within 35 days.

You will be in a position to assess the actions that provide your business with the best ROI over time, monitoring the progress and verifying the savings from one central dashboard. Cutting costs here will enable you to divert the funds to other areas of your business, including promotions, marketing, and product development.

For businesses in the energy sector- including electric, oil and gas plants, they specifically need carbon emission reports, to pinpoint areas where the building’s energy efficiency can be improved. ecoVaro EMS allows you to set alarms and KPIs in the facility for issues to be identified and resolved immediately they crop up.

Turn to ecoVaro

EMS systems are used across the board – from optimising energy use in hotel rooms and hospitals, mapping out usage patterns for those in the agriculture and supply chain niches, running facilities for utility providers, all through to increasing the efficiency of equipment operation for business in the food and beverage sector. Want to learn how you can cut down your energy bills and make your business more eco-friendly? EcoVaro’s team is ready to get you started.

What Kanban can do for Call Centre Response Times

When a Toyota industrial engineer named Taiichi Ohno was investigating ways to optimise production material stocks in 1953, it struck him that supermarkets already had the key. Their customers purchased food and groceries on a just-in-time basis, because they trusted continuity of supply. This enabled stores to predict demand, and ensure their suppliers kept the shelves full.

The Kanban system that Taiichi Ohno implemented included a labelling system. His Kanban tickets recorded details of the factory order, the delivery destination, and the process intended for the materials. Since then, Ohno?s system has helped in many other applications, especially where customer demand may be unpredictable.

Optimising Workflow in Call Centres
Optimising workflow in call centres involves aiming to have an agent pick up an incoming call within a few rings and deal with it effectively. Were this to be the case we would truly have a just-in-time business, in which operators arrived and left their stations according to customer demand. For this to be possible, we would need to standardise performance across the call centre team. Moving optimistically in that direction we would should do these three things:

Make our call centre operation nimble
Reduce the average time to handle calls
Decide an average time to answer callers

When we have done that, we are in a position to apply these norms to fluctuating call frequencies, and introduce ?kanbanned? call centre operators.

Making Call Centre Operations Nimble
The best place to start is to ask the operators and support staff what they think. Back in the 1960?s Robert Townsend of Avis Cars famously said, ?ask the people ? they know where the wheels are squeaking? and that is as true as ever.

Begin by asking technical support about downtime frequencies, duration, and causes. Given the cost of labour and frustrated callers, we should have the fastest and most reliable telecoms and computer equipment we can find.

Then invest in training and retraining operators, and making sure the pop-up screens are valuable, valid, and useful. They cannot do their job without this information, and it must be at least as tech-savvy as their average callers are.

Finally, spruce up the call centre with more than a lick of paint to awaken a sense of enthusiasm and pride. Find time for occasional team builds and fun during breaks. Tele-operators have a difficult job. Make theirs fun!

Reducing Average Time to Handle Calls
Average length of contact is probably our most important metric. We should beware of shortening this at the cost of quality of interaction. To calculate it, use this formula:

Total Work Time + Total Hold Time + Total Post Call Time

Divided By

Total Calls Handled in that Period

Share recordings of great calls that highlight how your best operators work. Encourage role-play during training sessions so people learn by doing. Publish your average call-handling time statistics. Encourage individual operators to track how they are doing against these numbers. Make sure your customer information is up to date. While they must confirm core data, limit this so your operators can get down to their job sooner.

Decide a Target Time to Answer Calls
You should know what is possible in a matter of a few weeks. Do not attempt to go too tight on this one. It is better to build in say 10% slack that you can always trim in future. Once you have decided this, you can implement your Kanban system.

Introducing Kanban in Your Call Centre Operation
Monitor your rate of incoming calls through your contact centre, and adjust your operator-demand metric on an ongoing basis. Use this to calculate your over / under demand factor. Every operator should know the value on this Kanban ticket. It will tell them whether to speed up a little, or slow down a bit so they deliver the effort the call rate demands. It will also advise the supervisor when to call up reserves.

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How COBIT helps you achieve SOX Compliance

First released way back in 1996, COBIT has already been around for quite a while. One reason why it never took off was because companies were never compelled to use it ? until now. Today, many CEOs and CIOs are finding it to be a vital tool for achieving SOX compliance in IT.

Thanks to SOX, COBIT (Control Objectives for Information and related Technology) is now one of the most widely accepted source of guidance among companies who have IT integrated with their accounting/financial systems. It has also gained general acceptability with third parties and regulators. But how did this happen?

Role of control frameworks in SOX compliance

You see, the Sarbanes-Oxley Act, despite having clearly manifested the urgency of establishing effective internal controls, does not provide a road map for you to follow nor does it specify a yardstick to help you determine whether an acceptable mileage in the right direction has already been achieved.

In other words, if you were a CIO and you wanted to find guidance on what steps you had to take to achieve compliance, you wouldn’t be able to find the answers in the legislation itself.

That can be a big problem. Two of your main SOX compliance obligations as a CEO or CIO is to assume responsibility in establishing internal controls over financial reporting and to certify their effectiveness. After that, the external auditors are supposed to attest to your assertions. Obviously, there has to be a well-defined basis before you can make such assertions and auditors can attest to anything.

In the language of auditors, this ?well-defined basis? is known as a control framework. Simply put, once you certify the presence of adequate internal controls in your organisation, the external auditor will ask, ?What control framework did you use??

Knowing what control framework you employed will help external auditors determine how to proceed with their evaluations and tests. For your part, a control framework can serve as a guide to help you work towards specific objectives for achieving compliance. Both of you can use it as a common reference point before drawing any conclusions regarding your controls.

But there are many control frameworks out there. What should you use?

How SOX, COSO, and COBIT fit together

Fortunately, despite SOX?s silence regarding control frameworks, you aren’t left entirely to your own devices. You could actually take a hint from the SEC and PCAOB, two of the lead organisations responsible for implementing SOX. SEC and PCAOB point to the adoption of any widely accepted control framework.

In this regard, they both highly endorse COSO, a well-established internal control framework formulated by the Committee of Sponsoring Organisations of the Treadway Commission (COSO). Now, I must tell you, if you’re looking specifically for instructions pertaining to IT controls, you won’t find those in COSO either.

Although COSO is the most established control framework for enterprise governance and risk management you’ll ever find (and in fact, it’s what we recommend for your general accounting processes), it lacks many IT-related details. What is therefore needed for your IT processes is a framework that, in addition to being highly aligned with COSO, also provides more detailed considerations for IT.

This is where COBIT fits the bill.

How COBIT can contribute to your regulatory compliance endeavors

COBIT builds upon and adheres with COSO while providing a finer grain of detail focused on IT. You can even find a mapping between COBIT IT processes and COSO components within the COBIT document itself.

Designed with regulatory compliance in mind, COBIT lays down a clear path for developing policies and good practice for IT control, thus enabling you to bridge the gap between control requirements, technical issues, and business risks.

Some of the components you’ll find in COBIT include:

IT control objectives

These are statements defining specific desired results that, as a whole, characterise a well-managed IT process. They come in two forms for each COBIT-defined IT process: a high-level control objective and a number of detailed control objectives. These objectives will enable you to have a sense of direction by telling you exactly what you need to aim for.

Maturity models

These are used as benchmarks that give you a relative measurement stating where your level of management or control over an IT process or high-level control objective stands. It serves as a basis for setting as-is and to-be positions and enables support for gap analysis, which determines what needs to be done to achieve a chosen level. Basically, if a control objective points you to a direction, then its corresponding maturity model tells you how far in that direction you’ve gone.

RACI charts

These charts tell you who (e.g. CEO, CFO, Head of Operations, Head of IT Administration) should be Responsible, Accountable, Consulted, and Informed for each activity.

Goals and Metrics

These are sets of goals along with the corresponding metrics that allow you to measure against those goals. Goals and metrics are defined in three levels: IT goals and metrics, which define what business expects from IT; process goals and metrics, which define what the IT process should deliver to support It’s objectives; and activity goals and metrics, which measure how well the process is performing.

In addition to those, you’ll also find mappings of each process to the information criteria involved, IT resources that need to be leveraged, and the governance focus areas that are affected.

Everything is presented in a logical and manageable structure, so that you can easily draw connections between IT processes and business goals, which will in turn help you decide what appropriate governance and control is needed. Ultimately, COBIT can equip you with the right tools to maintain a cost-benefit balance as you work towards achieving SOX compliance.