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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Six Sigma

Six Sigma has received much attention worldwide as a management strategy that is said to have brought about huge improvements and financial gains for such big-name companies as Allied Signal, General Electric (GE) and Motorola.

If you want to give your business the chance to attain the same resounding success, Six Sigma could be the method that will steer you towards that direction.

What is Six Sigma?

So what really is it? Six Sigma is a business management tool that was developed using the most effective quality improvement techniques from the last six decades. Basing its approach on discipline, verifiable data, and statistical calculations, Six Sigma aims to identify the causes of defects and eliminate them, thereby resulting in near-perfect products that meet or exceed customer’s satisfaction.

The core concept behind the Six Sigma method is that if an organisation can quantify the number of “defects” there are in a particular process, improvement activities can be implemented to eliminate them, and get as close to a “zero defects” scenario as possible. Defect here is defined as any process output that fails to meet customer specifications.

Six Sigma is also unique from other programs in that it calls for the creation of a special infrastructure of people within the organisation (“Champions“, “Black Belts“, “Green Belts“) who are to be expert in the methods.

Six Sigma Methodologies

When implementing Six Sigma projects, two methodologies are often employed. Although each method uses five phases each, these two are distinguished from each other using 5-letter acronyms and their specific uses.

DMAIC ? is the project methodology used to improve processes and maximise productivity of current business practices. The 5 letters stand for:

  • D ? Define (the problem)
  • M ? Measure (the main factors of the existing process)
  • A ??Analyse?(the information gathered to deter mine the causes of defects)
  • I ? Improve (the current process based on the analysis)
  • C ? Control (all succeeding processes so as to minimise additional defects)

DMADV – is the method most suitable if your business is looking to create new products or designs. The acronym stands for:

  • D ? Define (product goals as the consumer market demands)
  • M ? Measure (and identify product capabilities and risks)
  • A ??Analyse?(to create the best possible design)
  • D ? Design (the product or process details)
  • V ? Verify (the design)

How does Six Sigma differ from other quality programs?

If you think that Six Sigma is just another one of those business strategies that produce more hype than actual results, think again. Six Sigma uses three key concepts that sets it apart from other business management methods.

  • It is strictly a data-driven approach, where assumptions and guesswork do not figure in the decision making.
  • It focuses on achieving quantifiable financial results ? the bottom line ($) ? as much as giving emphasis on customer satisfaction.
  • It requires strong management leadership, while at the same time creating a role for every individual in the organisation.

Is Six Sigma right for your business?

While many other organisations such as Sony, Nokia, American Express, Xerox, Boeing, Kodak, Sun Micro-systems and many other blue chip companies have followed suit in adopting Six Sigma, the truth is, any company — whether you have a large manufacturing corporation, or a small business specialising in customer service.

Certainly, there is a lot more to Six Sigma than what you can probably absorb in one sitting or reading.

With our wide range of business management consultancy services, we can help you understand the Six Sigma method in the context of your business. We can also help you establish your improvement goals, set up your program, and train your own team of “champions” who can lead in implementing your Six Sigma goals.

Find out more about our Quality Assurance services in the following pages:

How Bouygues manages an Empire-Sized Footprint

Bouygues is into telecoms / media, and building and road construction. It also knows it has to watch its energy footprint closely. Owning 47% of energy giant Alstom keeps it constantly in the media spotlight. Shall we find out more about its facility management policies?

The journal Premises and Facilities Management interviewed MD Martin Bouygues on his personal opinions concerning managing energy consumption in facilities. He began by commenting that this was hardly a subject for the C-Suite in years gone by. Low-level clerks simply paid the bills following which the actual amounts were lost in the general expenses account. That of course has changed.

Early pressure came from soaring energy bills, which were pursued by a whole host of electricity-saving gadgets. However, it was only after the carbon crisis caught business by surprise that the link was forged to aerial pollution, and the social responsibilities of big business to help with the solution. The duty to have an energy strategy became an obligation eagerly policed by organisations such as Greenpeace.

Unsurprisingly, Martin Bouygues? advice begins with keeping energy consumption and its carbon footprint as high up on the agenda as health and safety. ?It needs bravery and a lot of hard work to get it there,? he says, ?so perseverance is the key?. 

The company has developed proprietary software that enables it to pull data from remote sensors in more than 80 countries every fifteen minutes. A single large building can contribute 50 million data items annually making data big business in the system. Every building has an allocated energy performance contract against which results are reported monthly, as a basis for reviewing progress.

The system is intelligent and able to incorporate low-occupancy periods such as weekends and public holidays. What is measured gets managed. We all know that, but how many of us apply the principle to our energy bills. With assistance from ecoVaro, the possible becomes real.

We offer a similar service to the Bouygues model with one notable exception. You don’t buy the software and you only pay when you use it. Our systems are simply designed for busy financial managers.

What are Operational Reviews

Faced with growing competition, businesses continually need to find new innovative solutions and ideas to improved organizational performance, especially in various cut-throat industries where innovation and good management can make or break the company.

This is the reason why, businesses place greater emphasis on the evaluation of efficiency, effectiveness, and economics of its operations.

Conducting regular Operational Reviews are key to keeping your company at peak performance.

What is an Operational Review

An operational review is an in-depth and objective review of an entire organization or a specific segment of that organization. It can be used to identify and address existing concerns within your company such as communication issues between departments, problems with customer relations, operating procedures, lack of profitability issues, and other factors that affect the stability of the business.

Operational reviews allow the organization members to evaluate how well they are performing, given that they perform appropriately according to the procedures set by them, allocating their resources properly, and performing such tasks within time frame set and using cost-effective measures. More importantly, it also shows your company how well it is prepared to meet future challenges.

What are the objectives of an Operational Review

The goals of an operational review are to increase revenue, improve market share, and reduce cost.

An operational review allows the management to see their company in a different light i.e a larger perspective. That is, it gives the management the opportunity to evaluate if the entrusted resources were used wisely to achieve the desired results of operations.

Operational reviews provide a comprehensive assessment of authority in that they help define expectations, and empower people within an organization to enact? up on it. This is due feedback provided will help them to better gauge the value of tasks performed and whether the job is being done the right or wrong way, and on what areas the company can excel and improve on.

The whole is greater than the sum of its parts

Questions worth considering in an Operational Review

Are you able to view your own organization as a whole from an objective angle?

Do the different departments complement each other so that they form a cohesive unit that boosts your business in the right direction?

With our comprehensive assessment of your organization?s current systems, operations, processes, and strategies, our operational review programs aim to help you in achieving these lofty goals: to improve business profitability and identify incompetence in both operations and organizational systems.

Benefits of an Operational Review

The main objective of an operational review is to help organizations like yours to learn how to deal with and address issues, instead of simply reacting to the challenges brought about by growth and change.

Information and data gathered in an Operational Review is practical from both a financial and operational perspective. Using? data, management can then formulate recommendations, which are not only realistic, but more importantly, can help the organization achieve its goals.

The Operational Review recognizes the extent to which your internal controls actually work, and enables you to identify and understand your strengths, weaknesses, opportunities and threats.

What should be included in an operational review

  • Assess compliance within your own organizational objectives, policies and procedures
  • Evaluate specific company operations independently and objectively
  • Impartial assessment regarding the effectiveness of an organization’s control systems
  • Identify the appropriate standards for quantifying achievement of organizational objectives
  • Evaluate the reliability and value of the company’s management data and reports
  • Pinpoint problem areas and their underlying causes
  • Identify opportunities to increase profit, augment revenue, and reduce costs without sacrificing the quality of the product or service.

More Operational Review Blogs

 

Carrying out an Operational Review

 

Operational Reviews

 

Operational Efficiency Initiatives

 

Operational Review Defined

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