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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Are Target Operating Models strategic compasses?

The short answer is they usually are, because every organisation needs a road-map of where they are going. Target operating models can be complex documents with illustrative details including project management structures, special tools, implementation procedures and management metrics. They can also be simple statements, as for example Winston Churchill?s promise that ?we shall fight them on the beaches, on the landing grounds and in the fields? which gave Britain the strategic direction it needed.

Many initiatives unfortunately fail because managers are ?too busy? to bottom on what their target operating model should say, or simply don’t believe in paperwork. As a result, promising initiatives may blunder off course or die a slow death without them really noticing. We cannot manage what we cannot measure, which is where the management metrics fit in. One of my favourite quotes is ?if you don’t know where you are going any road will get you there? which is what the Cheshire Cat said to Alice in Wonderland when she got lost.

The author blundered through life without a plan because there was no one else with his particular brand of imagination. The current business climate is different because everybody is trying to ramp up, and investors want to know exactly what is going to happen to their money and by when. Hence a target operating model can be indispensable throughout a change or product cycle.

The benefits of having a measurable operations / technology plan can produce powerfully tangible results if the organisation follows through on it. Built-in metrics with milestones are powerful tool for management, and, when they map through to the company financial plan almost irreplaceable as cash-flow forecasters.

Other benefits may include:

  • Shorter times to market and greater agility when launching new ideas
  • Reduced investor risk through a predictable process that’s readily monitored
  • A stable operating environment where there is consensus on direction
  • Greater likelihood of delivering on time and leading to repeat orders
  • A more cost-effective process, with less risk of loss of quality and money

Although it dates back a few years the Wills UK and Ireland Retail model still provides an excellent benchmark of a target operating plan that worked. The strategic goals were exceptionally clear, and they brought in a proven project manager to help them drive the program forward.

We have delivered advanced business management services to many of our clients, and believe you will find our personalised approach time-efficient and effective too.

8 Reasons why you Need to Undertake Technical and Application Assessments

Are your information assets enabling you to operate more cost-effectively or are they just drawing in more risks than you are actually aware of? Obviously, you now need to get a better picture of those assets to see if your IT investments are giving you the benefits you were expecting and to help you identify areas where improvements should be made.

The best way to get the answers to those questions is through technical and application assessments. In this post, we?ll identify 8 good reasons why it is now imperative to undertake such assessments.

1. Address known issues – Perhaps the most common reason that drives companies to undertake a technology/application assessment is to identify the causes of existing issues such as those related to data accessibility, hardware and software scalability, and performance.

2. Cut down liabilities and risks – Unless you know what and where the risks are, there is no way you can implement an appropriate risk mitigation strategy. A technology and application assessment will enable you to thoroughly test and examine your information systems to see where your business-critical areas and points of failure are and subsequently allow you to act on them.

3. Discover emerging risks – Some risks may not yet be as threatening as others. But it would certainly be reassuring to be aware if any exist. That way, you can either nip them in the bud or keep them monitored.

4. Comply with regulations – Regulations like SOX require you to establish adequate internal controls to achieve compliance. Other regulations call for the protection of personally identifiable information. Assessments will help you pinpoint processes that lack controls, identify data that need protection, and areas that don’t meet regulatory requirements. This will enable you to act accordingly and keep your company away from tedious, time-consuming and costly sanctions.

5. Enhance performance – Poor performance is not always caused by an ageing hardware or an overloaded infrastructure. Sometimes, the culprits are: unsuitable configuration settings, inappropriate security policies, or misplaced business logic. A well-executed assessment can provide enough information that would lead to a more cost-effective action plan and help you avoid an expensive but useless purchase.

6. Improve interoperability – Disparate technologies working completely separate from each other may be preventing you from realising the maximum potential of your entire IT ecosystem. If you can examine your IT systems, you may be able to discover ways to make them interoperate and in turn harness untapped capabilities of already existing assets.

7. Ensure alignment of IT with business goals – An important factor in achieving IT governance is the proper alignment of IT with business goals. IT processes need to be assessed regularly to ensure that this alignment continues to exist. If it does not, then necessary adjustments can be made.

8. Provide assurance to customers and investors – Escalating cases of data breaches and identity theft are making customers and investors more conscious with a company?s capability of preserving the confidentiality of sensitive information. By conducting regular assessments, you can show your customers and investors concrete steps for keeping sensitive information confidential.

EU Energy Efficiency Directive & UK?s ESOS

In 2012 the European Union passed its EU Energy Efficiency Directive (EED) into law. This aims to reduce overall energy consumption by 20% by 2020. It placed an obligation on member states to pass back-to-back local legislation by June 2014.

EED Guidelines

The EED provides specific guidelines it expects member nations to address. The list is long and here are a few excerpts from it:

  • Large companies must use energy audits to identify ways to cut their energy consumption
  • Small and medium companies must be incentivised to voluntarily take similar steps
  • Public sector bodies must purchase energy-efficient buildings, products and services
  • Private energy-consumers must be empowered with information to help manage demand
  • Energy distributors / resellers must cut their own consumption by 1.5% annually
  • Legislators are free to substitute green building technology e.g. through better insulation
  • Every year, European governments must audit 3% of the buildings they own

Definition of Energy Audit

An energy-consumption audit is a question of measuring demand throughout a supply grid, with particular attention to individual modules and high demand equipment. While this could be an exercise repeated every four years to satisfy ESOS, it makes more sense to incorporate it into the monthly energy billing cycle.

Because energy use is not consistent but varies according to production cycle, this can produce reams of printouts designed to frustrate busy managers. ecoVaro offers an inexpensive, cloud-based analytic service that effortlessly accepts client data and returns it in the form of high-level graphic summaries.

Potential ESOS Beneficiaries

As many as 9,000 UK companies are obligated to do energy audits because they employ more than 250 employees, have a balance sheet total over ?36.5m or an annual turnover in excess of ?42m. Any smaller enterprise that finds energy a significant input cost, should also consider enlisting Ecovaro to help it to:

  • Obtain a better understanding of the energy side of their business
  • Achieve energy savings and share in a estimated ?3bn bonanza to 2030
  • Reduce carbon emissions to help meet their CRC commitments

More About ecoVaro

We offer web-based energy management software that helps you measure and manage energy costs. This strips data from your meters and generates personalised reports on a dashboard you control. This information helps you accurately zoom in on worthwhile opportunities. With Ecovaro on your side, ESOS truly becomes an Energy Saving OPPORTUNITY Scheme.

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