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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Can you do away with the Project Initiation Meeting?

Project initiation meetings are often skipped to fast-track projects. Once a sponsor is found, organisations go straight to project planning and execution. But based on our own experience, holding a project initiation meeting can actually eliminate many issues that may crop up in the future and hence may speed things up instead in the long run.

It is in the project initiation meeting where your project objectives and scope are clarified and all stakeholders are brought to the same page. Project sponsors and stakeholders will have to know in a nutshell what is needed from them, what the possible risks are, what different resources are required, and so on. So that, when it’s time to proceed to the next phase, everyone is already in-sync.

So what are taken up in such a meeting? Perhaps an actual example can help. Sometime in the past, we set out to work on an eCommerce website project. After conducting the project initiation meeting, these were some of the things we were able to accomplish:

  • Identified deliverables e.g. site design, interface to payment system, etc.
  • Come up with the project phases
  • Agreed what should be in and out of scope
  • Defined the acceptance test criteria
  • Identified possible risks
  • Identified the possible training and documentation work needed
  • Established whether any analysis was required, e.g. as with regards to payment interfaces
  • Formulated disaster recovery plans
  • Defined roles and responsibilities
  • Drafted timelines and due dates

Aren’t these covered in project planning? If the project is a big one, the answer is no. In a large project, project planning is a much more exhaustive activity. In a project initiation meeting, only the basic framework is defined.

Some questions may still remain unanswered after a project initiation meeting, but at least you already know what answers you need to look for. In the example we gave earlier, we left the meeting knowing that we needed:

  • a list of all necessary hardware to estimate the costs
  • to identify possible dependencies we might have with third parties
  • to identify what software had to be bought and what skills we needed to hire

When it was time to proceed to project planning, everyone involved already knew what direction we were taking. In effect, by not skipping the project initiation meeting, we were able to avoid many potential obstacles.

ISO in Energy management

Every industry has its own set levels of quality that are considered acceptable or desirable. Energy performance like any other field is governed by some set standards. These differ across regions but international standards do exist.

ISO 50001 is the international energy standard applicable to both large and small organisations irrespective of geographical, cultural or social conditions. It outlines the best energy management practices that are considered to be the best by specifying that an organisation must integrate an energy management system and institute an energy policy, objectives, targets, and action plans taking into account legal requirements and information related to significant energy use. The energy standard is applicable to organisations.

What’s the importance of attaining energy certification?

ISO certification in any industry is a demonstration of quality or that a service or product meets the expected service standards. In energy management, ISO certification is a demonstration that an organisation or company has implemented sustainable energy management systems, completed a baseline of energy use and, is committed to continuously improve its energy performance. In addition, ISO certification assists organisations in the following ways:

? Organisations are able to optimise the existing energy-consuming assets

? Offers guidance on bench-marking, measuring, documenting, and reporting energy intensity improvements and their projected impact on reducing GHG emissions

? Creates transparency and facilitates communication on the management of energy resources

? Promotes energy management best practices and reinforces good energy management behaviours

? Assists facilities in evaluating and prioritising the implementation of new energy-efficient technologies

? Provides a framework for promoting energy efficiency throughout the supply chain

? Facilitates energy management improvements in the context of GHG emission reduction projects: The reduction of carbon emissions means therefore an organisation is able to meet government carbon reduction targets by demonstrating environmental credentials. The accruing benefits are many, ranging from increased investor confidence to more tender opportunities

Energy management software plays a vital role in helping organisations comply with energy standards through improved performance across the various functions in an organisation.

Outsourcing

Are you ready to outsource? Do you even need to outsource? We’ll help you answer those and other questions regarding outsourcing and your company.

Once we’ve determined that outsourcing will render your organisation more focused on your core competencies, more cost-effective, and more flexible, we’ll offer you the full spectrum of our services. Our specialists can assist you in every stage of the entire outsourcing life-cycle.

Starting from evaluating what can be outsourced, through finding the right outsourcing service provider, building the contract and agreements, getting everything in place, and managing the outsourcing relationship – we’ll be with you every step of the way.

Learn more about some of the outsourcing services we offer:

Outsourcing Contracts and Agreements

When an outsourcing project fails, both customer and service provider are quick to put the blame on the other party. But in most cases, the actual culprit was really just sitting there since day one – a poorly planned and implemented agreement.

We understand how costly and disruptive a failed outsourcing project can be for your business. That is why we put utmost attention to each contract and SLA (Service Level Agreement) that our customers enter into. This always reduces the likelihood of having unmet expectations, one of the major reasons why some outsourcing relationships fail.

We make sure that each agreement is fair, not only for our customers but also for the service providers themselves. Why? Because a disadvantaged provider will most likely end up delivering poor service as an offshoot of efforts to improve its profitability and ROI.

To accomplish this, we’ll thoroughly assess the infrastructure, resources, and expertise of your potential service provider to ensure they have the capability to meet your expectations. We’ll also make sure that their expectations are realistic and clear to you as well.

Here’s what you can expect from us when we start managing your outsourcing contracts and agreements:

  • A thorough assessment of your specific needs and the service provider’s profile to determine whether you have the right match before proceeding with any agreement.
  • Professional assistance when the time comes for you to discuss the scope of work, expected service levels, and when negotiating for appropriate pricing. We’ll also help you set up provisions for possible changes in the scope later on.
  • Expert counsel during drafting and finalisation of the contract and Service Level Agreements. Whenever applicable, we’ll help you propose penalties whenever service levels are not met and rewards when they are exceeded.
  • Regular reviews to determine whether everything agreed upon in the past, like pricing and service levels, are still realistic or competitive enough in view of current technological advancements and the prevailing social and economic environment.
  • Mediation expertise whenever the outsourcing project appears to be falling apart. We’ll work with you and the service provider to resolve conflicts and avoid the expensive exercise of having to terminate the contract. But if the best solution is to part ways, we’ll make sure you make an exit with the least disruption, missed opportunities and financial loss.

Application Outsourcing

I’m sure you’ve come to realise that to gain competitive advantage these days, you really need to invest in IT applications.

There are applications for enhancing your customer relationships, speeding up production, streamlining processes, advancing collaboration, protecting your systems from malware and many more. Selecting the right application, testing it, implementing it into your system, and then managing it can deviate resources which would have otherwise been used in other areas to build business value, increase profits, and enhance innovation.

Wouldn’t it be nice to unload yourself of the management processes which usually accompany IT applications? Actually, you can – through application outsourcing. Application outsourcing providers possess the expertise to either partially or fully assume responsibility of your IT applications.

Our job is to see to it that you link up with the provider who can best answer your needs. The overall proficiency of these providers spans both proprietary and opensource solutions, allowing them to cater to a wide range of preferences and budgetary limits. At the very least, they can provide professional support for well established applications.

If needed, they can develop applications for your organisation, taking charge of every step in the system development life-cycle: starting from system initiation, requirements analysis, through design, construction, acceptance and eventually to implementation.

Here are some of the benefits you can enjoy once we start managing your application outsourcing initiatives:

  • Freedom from time-consuming tasks such as installations, upgrades, configurations and repairs.
  • Reduced total cost of ownership (TCO).
  • 24/7 support from well-trained personnel. This can substantially cut downtimes caused by inexperienced troubleshooting.
  • The option to have your applications housed in more secure and reliable environments with much higher availability and much lower planned/unplanned downtimes.
  • Dedicated specialists who can focus on providing better regulatory compliance and risk mitigation initiatives.

Infrastructure Outsourcing

Keeping up with the competition nowadays usually requires technological advancements as well as the capability to manage and maintain the infrastructure that has to support them. These undertakings can suck your resources dry.

If you’re looking to reduce costs even while improving the performance of your networks, servers, databases, firewalls, desktops and mobile devices, you might want to consider IT infrastructure outsourcing among your top options. Infrastructure outsourcing service providers have the resources dedicated to a stable, secure, scalable and always available IT infrastructure.

Typical service provider facilities include data centrers equipped with high-speed networks, reliable power, dependable security, as well as provisions for upgrades, consolidation, disaster recovery, or even business continuity.

These providers employ specialists and staff who can manage and maintain all of these for you. While your provider juggles your core IT-related tasks, you can keep your eye on the ball and refocus on your company’s business goals.

Here are some of the benefits you can enjoy out of infrastructure outsourcing:

  • Freedom from time-consuming tasks such as installations, upgrades, configurations and repairs.
  • Since service providers, who are expected to have better horizontal and vertical scalability, will deal with the technological intricacies, your company’s strategic development initiatives can proceed unhampered.
  • Greatly reduced electricity expenses as a result of consolidation.
  • Easier, faster, cheaper, and more reliable disaster-recovery solutions through virtualisation.
  • Lesser risks of disruptions caused by power outages, cyber attacks, or Internet connection downtimes.

Business Process Outsourcing

With the sheer number of business processes your company has to attend to, it wouldn’t be surprising if you rarely have room to innovate.

Through business process outsourcing, we can free a considerable part of your financial and manpower resources which are currently focused on routine activities. With more resources to drive innovative initiatives, you’ll be able to accelerate production, improve customer service, enhance overall business value, and arrive at a stronger bottom line.

Some of the business processes that may be outsourced include data entry, finance and accounting, form processing, procurement, and HR, among others. If you’re interested in finding answers to the what, how, who, and where of BPO, specific to your organisation, we’ll be happy to enlighten you.

Here are some of the benefits you can enjoy once we start managing your BPO initiatives:

  • Professional guidance to ensure that your BPO undertakings will really result in substantial savings and significant improvements to your organisation’s business value.
  • Careful monitoring of service levels to ensure faster turnaround, accurate data, and high quality outputs.
  • Expert evaluation of information handling processes to guarantee full confidentiality.
  • Professional and unbiased management dedicated to establishing a strong, reliable, and fruitful relationship between you and your provider.

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