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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Why Predictive Maintenance is More Profitable than Reactive Maintenance

Regular maintenance is needed to keep the equipment in your facility operating normally. All machinery has a design lifespan, and your goal is to extend this as long as possible, while maintaining optimal production levels. How you go about the maintenance matters, from routine checks to repairing the damaged component parts?all before the whole unit needs to be tossed away and a new one purchased and installed. Here, we will break down the different approaches used, and show you why more industries and businesses are turning to proactive maintenance modes as opposed to the traditional reactive approaches for their?field service operations.?

Reactive Maintenance: A wait and see game

Here, you basically wait for a problem to occur, then fix it. It’s also commonly referred to as a “Run-to-Failure” approach, where you operate the machines and systems until they break. Repairs are then carried out, restoring it to operational condition.?

At face value, it appears cost-effective, but the reality on the ground is far much different. Sure, when the equipment is new, you can expect minimal cases of maintenance. During this time, there?ll be money saved. However, as time progresses there?ll be increased wear, making reliance on a reactive maintenance approach a costly endeavour. The breakdowns are more frequent, and inconsistent as well. Unplanned expenses increase operational costs, and there will be lost productivity during the periods in which the affected machinery won’t be in operation.?

While reactive maintenance makes sense when you’re changing a faulty light bulb at home, things are more complicated when it comes to dealing with machinery in industries, or for those managing multiple residential and commercial properties. For the light bulb, it’s easier to replace it, and failure doesn’t have a ripple effect on the rest of the structures in the household. For industries, each time there is equipment failure, you end up with downtime, production can grind to a halt, and there will be increased environmental risks during equipment start-up and shutdown. If spare parts are not readily available, there will be logistical hurdles as you rush the shipping to get the component parts to the facility. Add this to overworked clients in a bit to complete the repair and to make up for lost hours and delayed customer orders.

For field service companies, more time ends up being spent. After all, there?s the need of knowing which parts needed to be attended to, where they are, and when the servicing is required. Even when you have a planned-out schedule, emergency repairs that are required will force you to immediately make changes. These ramps up the cots, affecting your operations and leading to higher bills for your client. These inconveniences have contributed to the increased reliance on?field service management platforms that leverage on data analytics and IoT to reduce the repair costs, optimise maintenance schedules, and?reduce unnecessary downtimes?for the clients.

Waiting for the machinery to break down actually shortens the lifespan of the unit, leading to more replacements being required. Since the machinery is expected to get damaged much sooner, you also need to have a large inventory of spare parts. What’s more, the damages that result will be likely to necessitate more extensive repairs that would have been needed if the machinery had not been run to failure.?

Pros of reactive maintenance

Less staff required.
Less time is spent on preparation.

Cons of reactive maintenance

Increased downtime during machine failure.
More overtime is taken up when conducting repairs.
Increased expenses for purchasing and storing spare parts.?
Frequent equipment replacement, driving up costs.?

This ?If it ain’t broke, don’t fix it? approach leads to hefty repair and replacement bills. A different maintenance strategy is required to minimise costs. Proactive models come into focus. Before we delve into predictive maintenance, let’s look at the preventive approach.?

Preventive Maintenance: Sticking to a timetable

Here, maintenance tasks are carried out on a planned routine?like how you change your vehicle?s engine oil after hitting a specific number of kilometres. These tasks are planned in intervals, based on specific triggers?like a period of time, or when certain thresholds are recorded by the meters. Lubrication, carrying out filter changes, and the like will result in the equipment operating more efficiently for a longer duration of time. While it doesn’t completely stop catastrophic failures from occurring, it does reduce the number of failures that occur. This translates to capital savings.??

The Middle Ground? Merits And Demerits Of Preventive Maintenance

This periodic checking is a step above the reactive maintenance, given that it increases the lifespan of the asset, and makes it more reliable. It also leads to a reduced downtime, thus positively affecting your company?s productivity. Usually, an 80/20 approach is adopted,?drawing from Pareto’s Principle. This means that by spending 80% of time and effort on planned and preventive maintenance, then reactive maintenance for those unexpected failures that pop up will only occur 20% of the time. Sure, it doesn’t always come to an exact 80/20 ratio, but it does help in directing the maintenance efforts of a company, and reducing the expenses that go into it.?

Note that there will need to be a significant investment?especially of time, in order to plan a preventive maintenance strategy, plus the preparation and delegation of tasks. However, the efforts are more cost effective than waiting for your systems and machinery to fail in order to conduct repairs. In fact, according to the US Dept. of Energy, a company can save between 12-18 % when using a preventive maintenance approach compared to reactive maintenance.

While it is better than the purely reactive approach, there are still drawbacks to this process. For instance, asset failure will still be likely to occur, and there will be the aspect of time and resource wastage when performing unneeded maintenance, especially when technicians have to travel to different sites out in the field. There is also the risk of incidental damage to machine components when the unneeded checks and repairs are being carried out, leading to extra costs being incurred.

We can now up the ante with predictive maintenance. Let’s look at what it has to offer:

Predictive Maintenance: See it before it happens

This builds on preventive maintenance, using data analytics to smooth the process, reduce wastage, and make it more cost effective. Here, the maintenance is conducted by relying on trends observed using data collected from the equipment in question, such as through vibration analysis, energy consumption, oil analysis and thermal imaging. This data is then taken through predictive algorithms that show trends and point out when the equipment will need maintenance. You get to see unhealthy trends like excessive vibration of the equipment, decreasing fuel efficiency, lubrication degradation, and their impact on your production capacities. Before the conditions breach the predetermined parameters of the equipment’s normal operating standards, the affected equipment is repaired or the damaged components replaced.??

Basically, maintenance is scheduled before operational or mechanical conditions demand it. Damage to equipment can be prevented by attending to the affected parts after observing a decrease in performance at the onset?instead of waiting for the damage to be extensive?which would have resulted in system failure. Using?data-driven?field service job management software will help you to automate your work and optimise schedules, informing you about possible future failures.

Sensors used record the condition of the equipment in real time. This information is then analysed, showing the current and future operational capabilities of the equipment. System degradation is detected quickly, and steps can be taken to rectify it before further deterioration occurs. This approach optimises operational efficiency. Firstly, it drastically reduces total equipment failure?coming close to eliminating it, extending the lifespan of the machinery and slashing replacement costs. You can have an orderly timetable for your maintenance sessions, and buy the equipment needed for the repairs. Speaking of which, this approach minimises inventory especially with regards to the spare parts, as you will be able to note the specific units needed beforehand and plan for them, instead of casting a wide net and stockpiling spare parts for repairs that may or may not be required. Repair tasks can be more accurately scheduled, minimising time wasted on unneeded maintenance.??

Preventive vs Predictive Maintenance?

How is predictive different from preventive maintenance? For starters, it bases the need for maintenance on the actual condition of the equipment, instead of a predetermined schedule. Take the oil-change on cars for instance. With the preventive model, the oil may be changed after every 5000?7500 km. Here, this change is necessitated because of the runtime. One doesn’t look at the performance capability and actual condition of the oil. It is simply changed because “it is now time to change it“. However, with the predictive maintenance approach, the car owner would ideally analyse the condition of the oil at regular intervals- looking at aspects like its lubrication properties. They would then determine if they can continue using the same oil, and extend the duration required before the next oil change, like by another 3000 kilometres. Perhaps due to the conditions in which the car had been driven, or environmental concerns, the oil may be required to be changed much sooner in order to protect the component parts with fresh new lubricant. In the long run, the car owner will make savings. The US Dept. of Energy report also shows that you get 8-12% more cost savings with the predictive approach compared to relying on preventive maintenance programs. Certainly, it is already far much more effective compared to the reactive model.?

Pros of Predictive Maintenance

Increases the asset lifespan.
Decreases equipment downtime.
Decreases costs on spare parts and labour.
Improves worker safety, which has the welcome benefit of increasing employee morale.
Optimising the operation of the equipment used leads to energy savings.
Increased plant reliability.

Cons of Predictive Maintenance

Initial capital costs included in acquiring and setting up diagnostic equipment.
Investment required in training the employees to effectively use the predictive maintenance technology adopted by the company.

The pros of this approach outweigh the cons.?Independent surveys on industrial average savings?after implementing a predictive maintenance program showed that firms eliminated asset breakdown by 70-75%, boosted production by 20-25%, and reduced maintenance costs by 25-30%. Its ROI was an average of 10 times, making it a worthy investment.

User-Friendly RASCI Accountability Matrices

Right now, you’re probably thinking that’s a statement of opposites. Something dreamed up by a consultant to impress, or just to fill a blog page. But wait. What if I taught you to create order in procedural chaos in five minutes flat? ?Would you be interested then?

The first step is to create a story line ?

Let’s imagine five friends decide to row a boat across a river to an island. Mary is in charge and responsible for steering in the right direction. John on the other hand is going to do the rowing, while Sue who once watched a rowing competition will be on hand to give advice. James will sit up front so he can tell Mary when they have arrived. Finally Kevin is going to have a snooze but wants James to wake him up just before they reach the island.

That’s kind of hard to follow, isn’t it ?

Let’s see if we can make some sense of it with a basic RASCI diagram ?

Responsibility Matrix: Rowing to the Island
Activity	Responsible	Accountable	Supportive	Consulted	Informed
Person	John	Mary	Sue	James	Kevin
Role	Oarsman	Captain	Consultant	Navigator	Sleeper

Now let’s add a simple timeline ?

Responsibility Matrix: Rowing to the Island
?	Sue	John	Mary	James	Kevin
Gives Direction	?	?	A	?	?
Rows the Boat	?	R	?	?	?
Provides Advice	S	?	?	?	?
Announces Arrival	?	?	A	C	?
Surfaces From Sleep	?	?	?	C	I
Ties Boat to Tree	?	?	A	?	?

Things are more complicated in reality ?

Quite correct. Although if I had jumped in at the detail end I might have lost you. Here?s a more serious example.

There?s absolutely no necessity for you so examine the diagram in any detail, other to note the method is even more valuable in large, corporate environments. This one is actually a RACI diagram because there are no supportive roles (which is the way the system was originally configured).

Other varieties you may come across include PACSI (perform, accountable, control, suggest, inform), and RACI-VS that adds verifier and signatory to the original mix. There are several more you can look at Wikipedia if you like.

Benefits of Integrating IoT and Field Service

Owing to the complexity of its definition, many people loosely use the phrase Internet of Things (IoT) without having a solid grasp of its true meaning. A majority in this category take IoT to be nothing more than the automation of home gadgets, where the internet is used to interconnect computing components embedded in everyday devices.

Granted, the whole idea of IoT got its roots from the home setting. Nevertheless, IoT has outgrown that spectrum and has since penetrated into almost every area of business and industry. By employing IoT, you can literally take full control of everything in your business using a single device. From assigning tasks to monitoring security, managing bills to tracking time, IoT has revolutionized the way business is done.

Interestingly, not so long ago, most technology experts limited their forecasts to machine-to-machine (M2M) integration and Augmented Reality (AR), which also, admittedly, hit the technology industry with an admirable suave. Back then, it could have been laughable for anyone to have suggested that IoT would be so commanding in almost every industry, including real estate, medicine, automobile, and more.

It’s not for nothing, therefore, that the field service industry has also embraced IoT, integrating it in the daily running of business activities, including tracking machine diagnostics, detecting breakdowns, and assigning field engineers to attend to customer needs.

How the Field Service Industry is Benefiting from IoT

Machine uptime has remained an ongoing concern for many customers. In the traditional approach, whenever a machine breaks down, the customer alerts the service provider and then the field service manager checks to see if there is any field engineer available for a new task. Once an engineer has been identified, he?s then dispatched to the site. This worked, but it resulted in an extended machine downtime, a terrible experience for customers.

Thanks to IoT, things are now happening differently.

IoT is now integrating machines to a central communications centre, where all alerts and status updates are sent. The notifications are instant. The field service manager, therefore, gets to learn of the status of machines at the exact time of status change. An engineer who?s not engaged would then be immediately assigned to undertake any needed servicing or repair.

By employing IoT, the service provider receives timely reports relating to diagnostics, machine uptime, part failures, and more. The field manager can, as a result, foretell and forestall any possible downtime.

How has this been helpful?

Before giving a definite answer to that question, it’s crucial to note that more than half of all field service organizations now employ IoT in their Asset Management Systems and Field Service Management. And to answer the question, all the organizations that have the two systems integrated using IoT experience twice as much efficiency as those that don’t, states an Aberdeen Group report. As you already know, improved efficiency results in a corresponding upshot in customer satisfaction.

Apps Making a Difference in IoT-Field Service

The integration of IoT into almost every aspect of business prompted the design and development of different applications to link computing devices. Since the advent of IoT, the software development for the technology has come of age. Powerful and lightweight apps that don simple yet beautiful user interfaces are now readily available at affordable price tags.

A good example of such an App is ecoVaro by Denizon.

ecoVaro not only helps businesses to monitor energy and other relevant environmental data such as Electricity, Gas, Water, Oil, Carbon, Temperature, Humidity, Solar Power, and more, but also provides analytics and comprehensive yet easy to understand reports. The data received from devices such as meters is converted into useful information that’s then presented in figures and graphs, thus allowing you to make decisions based on laid down controls.

The focus of the app is to instantly alert service engineers to go on site to fix issues.

With ecoVaro, field service engineers no longer have to return to the office to get new instructions. Also, customers don’t have to manually fire alerts to the service provider whenever something isn’t working correctly. By employing the latest in IoT, ecoVaro sends notifications to field service managers and engineers about respective customers that need support.

How ecoVaro Helps

Best-in-class companies aren’t ready to compromise on customer satisfaction. Therefore, every available avenue is used to address customer concerns with the deserved agility. By using IoT, ecoVaro makes it possible for field service providers to foresee and foreclose any possible breakdowns.

The inter-connectivity among the devices and the central communications centre results in increased revenue and improved interactivity between the system and the field engineers. This results in greater efficiency and lower downtime, which translates into improved productivity, accountability, and customer satisfaction, as well as creating a platform for a possible expansion of your customer base.

ecoVaro isn’t just about failed machines and fixes. It also provides diagnostics about connected systems and devices. With this, the diagnostics centre receives system reports in a timely manner, allowing for ease of planning and despatch of field officers where necessary.

Clearly, but using the right application, IoT can transform your business into an excellently performing field service company.