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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IT Transformation Defined

Businesses depend on IT to effectively manage business processes and to provide products and services to clients. As IT technologies advance, it is crucial that businesses update their hardware to remain competitive. But businesses should do more than simply upgrade their servers and should really strive to effect IT transformation.

What is IT Transformation?

IT transformation is the ongoing process of changing the way that a company uses IT to better align it with current business goals. Through the IT transformation process, businesses try to determine whether they are meeting mission-critical benchmarks through the incorporation of new IT technologies for corporate transformation.

For example, if one of the current business concerns is whether the company can improve customer service, the IT system will need to evolve in such a way that improves customer service in a measurable way.

Successfully Aligning the Technology to Business Goals

In order to successfully align the IT system with business goals, it is important to understand the newly integrated technologies to understand how they can change business processes. If a new feature is intended to make the server more secure, the management should know exactly how the feature will improve the security of the server and whether the new implementation is redundant.

Once the business objectives have been identified, IT transformation is carried out by changing both the software and hardware used by the company. An example would be the growing trend of server migration to the cloud. Cloud computing is the growing trend of making files and data accessible from anywhere. If an organisation believes that it can improve productivity through a server cloud migration, it will need a way to test this.

The IT Transformation Process

Given that IT transformation is directly related to the core business, the IT transformation process must begin by identifying which aspects of the company must be changed. Then, the company must determine?IT services that could potentially be integrated into the business in a way that will help the company achieve benchmarks. After the key decision-makers understand the IT network well enough to effectively implement it, the company must efficiently manage the transformation process. Then, after the IT has been integrated, the company must have a system in place to measure business transformation in a numerical way.

For example, when assessing customer satisfaction, one effective strategy would be to distribute customer satisfaction surveys that ask customers to rate their experiences on a scale of one to ten. The company can then measure the results of the customer satisfaction survey to determine whether the new IT implementations are accomplishing their intended goals.

If the expected benchmarks are not being met, the next step in the IT transformation process is to determine if there is a specific reason for that. Is there a way that the feature can be better integrated to achieve desired business objectives? Are there other features that can help the company better achieve its goals?

Upgrading a network can be an expensive process and it is important to identify early on which options are the most likely to benefit the company’s bottom line.

Top 3 reasons to get into Multi-Channel Retail

Multi-channel retail, which nowadays understandably includes online channels, is something you just have to do this year. Every single day you put off doing it, the competition gobbles up market share that should have been yours. There are a number of reasons why even successful retailers are now going into multi-channel retailing. Here?s three of the most important ones.

1. You’ll get a BIG jump in sales

Not counting this year, which could be getting a big boost from major activities like the Queen?s Diamond Jubilee and the 2012 Olympics, sales of UK retailers have been experiencing tremendous growth particularly from their online channels. Already two years ago (2010), a number of UK retailers boasted significant increases in sales as a result of multi-channel retail initiatives. These retailers included:

  • Argos, which got a whopping ?1.9bn from multichannel sales back then;
  • House of Fraser, which reported a 150% jump in its online sales in just 6 months; and
  • Debenhams, whose profits rose by 20%

There were many others. Now, the reason I?m showing you 2010 figures is because online retail sales increased by 14% in 2011 and those same businesses still added to that growth. So, if only you had enough foresight and started expanding your business to the Web two years ago, you could just imagine what your sales would have been today.

The good news is that, it’s not yet too late if you start now. Here?s why…

2. Those numbers are going to keep on growing

We’re getting all sorts of predictions from leading researchers regarding the possible growth of the Internet economy. All these predictions have one thing in common. They all have a positive outlook. The Boston Consulting Group (BCG), for instance, predicts an average growth of no less than 10% per year in the G-20 nations.

3. Most online retailers aren’t doing it right yet

Although many retailers have already started bringing their business to the Web, most of them are doing it the wrong way. For example, many of them fail to integrate their offline and online channels. This is a serious shortcoming because it leads to customer dissatisfaction.

When a customer goes to your website and sees something he likes, you wouldn’t want him to drive all the way to your store only to find out that the item isn’t available there or, if the item is there, that it isn’t priced as he expected. The lack of multi-channel integration is very common among multi-channel retailers.

These inadequacies are actually good news because it means there are still many areas you can improve on. After improving on them, you can then highlight those areas as your key differentiators.

If you’re still looking for more reasons on why you should go into multi-channel retailing, read this post:

“5 Numbers Showing Why the Time to Invest on eCommerce in the UK is Now”

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Is Change Management a Myth or a Possibility

The theory that it is possible to manage organisational change (Change Management) in a particular direction has done the rounds for quite some time, but is it true about Change Management. Was Barrack Obama correct when he said, ?Change will not come if we wait for some other person or some other time. We are the ones we have been waiting for. We are the change that we seek.?
Or, was business coach Kelly A Morgan more on the button when she commented, ?Changes are inevitable and not always controllable. What can be controlled is how you manage, react to, and work through the change process.? Let us consult the evidence and see what statisticians say.

What the Melcrum Report Tells Us

Melcrum are ?internal communication specialists who work alongside leaders and teams around the globe to build skills and best practice in internal communication.? They published a report after researching over 1,000 companies that attempted change management and advised:

? More than 50% report improved customer satisfaction

? 33% report higher productivity

? 28% report improvements in employee advocacy

? 27% improved status as a great place to work

? 27% report increased profitability

? 25% report improved absenteeism

Sounds great until we flip the mirror around and consider what the majority apparently said:

? 50% had no improvement in customer service

? 67% did not report increased productivity

? 72% did not note improvements in employee advocacy

? 73% had no improved status among job seekers

? 73% did not report increased profitability

? 75% did not report any reduction of employee absenteeism

This shows it is still a great idea to hear what all parties have to say before reaching a conclusion. You may be interested to know the Melcrum report gave rise to the legend that 70% of organisation change initiatives fail. This finding has repeated numerous times. Let’s hear what the psychologists have to say next.

There is a certain amount of truth in the old adage that says, ?You can lead a horse to water but you cannot make him drink.? Which of us has not said, ?Another flavour of the week ? better keep heads down until it passes? during a spell in the corporate world. You cannot change an organisation, but you can change an individual.

At the height of the Nazi occupation of 1942, French philosopher-writer Antoine de Saint-Exup?ry said, ?A rock pile ceases to be a rock pile the moment a single man contemplates it, bearing within him the image of a cathedral?. Psychology Today suggests five false assumptions change management rests upon, THAT ARE SIMPLY NOT TRUE.

1. The external world is orderly, stable, predictable and can be managed

2. Change managers are objective, and do not import their personal bias

3. The world is static and orderly and can be changed in linear steps

4. There is a neutral starting point where we can gather all participants

5. Change is worthy in itself, because all change is an improvement

Leo Tolstoy wrote, ?Everyone thinks of changing the world, but no one thinks of changing himself.? A prophet can work no miracles unless the people believe. From the foregoing, it is evident that change management of an organisation is a 70% impossibility, but encouraging an individual to grow is another matter.

A McKinsey Report titled Change Leader, Change Thyself fingers unbelieving managers as the most effective stumbling stones to change management. To change as individuals ? and perhaps collectively change as organisations ? we need to ?come to our own full richness?, and as shepherds lead our flock to their ?promised land?, whatever that may be. Conversely, herding our flock with a pack of sheepdogs extinguishes that most precious thing of all, human inspiration.

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