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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2015 ESOS Guidelines Chapter 1 ? Who Qualifies

The base criteria are any UK undertaking that employs more than 250 people and/or has a turnover in excess of ?50 million and/or has a balance sheet total greater than ?43 million. There is little point in attempting to separate off high polluting areas. If one corporate group qualifies for ESOS, then all the others are obligated to take part too. The sterling equivalents of ?38,937,777 and ?33,486,489 were set on 31 December 2014 and apply to the first compliance period.

Representatives of Overseas Entities

UK registered branches of foreign entities are treated as if fully UK owned. They also have to sign up if any overseas corporate element meets the threshold no matter where in the world. The deciding factor is common ownership throughout the ESOS system. ecoVaro appreciates this. We have seen European companies dumping pollution in under-regulated countries for far too long.

Generic Undertakings that Could Comply

The common factor is energy consumption and the organisation’s type of work is irrelevant. The Environmental Agency has provided the following generic checklist of undertakings that could qualify:

Limited Companies Public Companies Trusts
Partnerships Private Equity Companies Limited Liability Partnerships
Unincorporated Associations Not-for-Profit Bodies Universities (Per Funding)

Organisations Close to Thresholds

Organisations that come close to, but do not quite meet the qualification threshold should cast their minds back to previous accounting periods, because ESOS considers current and previous years. The exact wording in the regulations states:

?Where, in any accounting period, an undertaking is a large undertaking (or a small or medium undertaking, as the case may be), it retains that status until it falls within the definition of a small or medium undertaking (or a large undertaking, as the case may be) for two consecutive accounting periods.?

Considering the ?50,000 penalty for not completing an assessment or making a false or misleading statement, it makes good sense for close misses to comply.

Joint Ventures and Participative Undertakings

If one element of a UK group qualifies for ESOS, then the others must follow suit with the highest one carrying responsibility. Franchisees are independent undertakings although they may collectively agree to participate. If trusts receive energy from a third party that must do an ESOS, then so must they. Private equity firms and private finance initiatives receive the same treatment as other enterprises. De-aggregations must be in writing following which separated ESOS accountability applies.

Strategy and Portfolio Management

 

A well planned strategy is the necessary bridge between brilliant leadership and excellent execution. Without it, your entire organisation cannot hope to respond quickly and effectively to challenges and changes within the landscape on which it operates.

Strategic planning involves identifying objectives, understanding what resources are needed to attain them, and then allocating the resources to the appropriate units to ensure they are used optimally towards the achievement of desired objectives. Among the end results which can be reflected by your team members are:

  1. Deeper understanding of the competitive environment;
  2. Snappy execution of plans;
  3. Faster, more aligned actions; and
  4. More intelligent and apt responses against strategic moves of the competition.

We understand the need to institute strategic management in such a way that your organisation can easily adapt to unforeseen developments. As such, all our solutions are formulated to make your organisation not only well-guided but also as dynamic as possible.

Strategy Formulation

Before you can proceed to map out any strategy for your company, you’ll have to study your company’s current environment. This will help you determine what courses of action should be taken to be able to navigate through such environment on your way to the end goal.

If you’re not a full time strategist, such a task can either be very daunting or deceivingly easy… the former can prevent your team from getting started, while the latter can lead your team astray.

Ideally, strategy formulation should be carried out as quickly and as efficiently as possible so you can move on to implementation before the competition can react. Our methods can enable your leaders to hit the ground running each time they set out on a strategic plan.

How?

  • We can assist in accurately applying strategic tools like SWOT and Gap analysis, then help integrate the results into an effective strategic plan.
  • We’ll train your team how to carry out effective research techniques so that the information they gather will really be what we need. This is because the tools mentioned earlier can only work effectively if the inputs were picked intelligently. Of course, if you want the entire process expedited, we can also conduct the research ourselves.
  • We’ll establish best practices for top-down, bottom-up, and collaborative strategic management processes. We’ll even show you how to organise and hold meetings where team members are constantly engaged and in-sync, so action plans can be developed and relayed fast.
  • We’ll see to it that strategies for all functional departments (such as IT management, supply-chain, HR, marketing, and legal) are in line with your business strategies, which should in, turn be aligned with your overall corporate strategy.

Strategy Evaluation

Your strategies have to be periodically assessed if you want to determine whether they are attuned to variations affecting your organisation. These changes may include new technologies, emerging competitors, new opportunities, as well as unexpected developments in the economic environment and political climate.

While no time limit is imposed for the build-up of resources vital to the attainment of a specific objective, the window of opportunity can shut on you before you can start amassing such resources. Given this possibility, it is important for your strategies to undergo evaluation processes that will determine whether you should pursue them or not.

Using only the most reliable evaluation techniques, we’ll help you establish whether:

  • Your strategies will place your company in a position that will give it competitive advantage or will erode whatever advantage the competition already has;
  • Your strategies are consistent with the landscape on which your company currently traverses;
  • They are realistic enough in relation to the resources you have on hand;
  • The associated risks have all been identified and the appropriate control measures have already been put in place;
  • The time frames for their full realisation are both realistic and acceptable.

Portfolio Management

In today’s highly competitive market, many of the more successful enterprises are driven by project-based systems.

Now, there’s always a tendency for project managers to become overenthusiastic and to come up with a number of projects that can’t be sustained by available resources. If your project-based company frequently runs out of resources, then either you just have too many projects running or too much is being allocated to a select few.

In both instances, the problem does not necessarily lie on the individual project managers themselves. Rather, what is needed is the ability to have full control over existing projects and investments.

Your leadership should be able to rank projects in terms of their impact to your organisation’s growth, positioning, and profitability. This will give you sufficient information when deciding which projects to pursue, prioritise, or shut down. These are the benefits you’ll gain from our services:

  • A vivid presentation of the big picture. Only when you can step back from all the detail and see the interplay of investments and resources will you be able to make wise decisions regarding how and where to position them.
  • The ability to distinguish between projects with the highest potentials and those that are outdated.
  • Access to expertise that will help you distribute your present IT infrastructure, human resources, financial resources, and facilities across running projects to obtain the biggest benefits for all stakeholders.

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK
Align IT Investments With Organization Goals

While some organisation leaders loathe spending on IT, a growing number are already convinced of the necessity of investing in it. Unfortunately, a substantial fraction of those convinced to pursue IT investments are misguided as to which initiatives are really contributory to reaching their organisation’s goals.

In the end, many of their purchases either end up underutilised or become white elephants altogether. There are also those difficult to spot – IT purchases that do become integrated into daily operations but have little effect on the organisation’s growth, positioning, profitability, or efficiency.

If a purchase is to cost your company a fortune, then its positive impact on established company objectives should reflect accordingly. But how would you know it would? You can’t hope to foresee all its benefits especially if the IT solution is still quite new to you.

Our job is not only to identify the strengths of an IT system but also to determine whether these strengths are at all useful to your organisation’s thrusts.

Basically, here’s what we’ll do:

  • Conduct a rigorous analysis of your organisation to determine the specific and overall impact of certain IT solutions. We’ll be looking for areas where the effects of IT can result in the most rapid reduction of costs and, at the same time, drive the organisation in the direction of its established goals.
  • Propose cohesive best-of-breed solutions in line with the results of our analysis. Our familiarity with the IT landscape and our extensive selection of contacts in the industry will allow us to conduct insightful picks from a vast field of choices.
  • Establish best practices to make sure IT investments are optimally utilised.
  • Perform periodic reviews to ensure practices and processes are still in line with the established goals.

Find out how we can increase your efficiency even more:

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK

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