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 6 – Role of Lead Assessor

The primary role of the lead assessor is to make sure the enterprise?s assessment meets ESOS requirements. Their contribution is mandatory, with the only exception being where 100% of energy consumption received attention in an ISO 50001 that forms the basis of the ESOS report.

How to Find a Lead Assessor

An enterprise subject to ESOS must negotiate with a lead assessor with the necessary specialisms from one of the panels approved by the UK government. This can be a person within the organisation or an third party. If independent, then only one director of the enterprise need countersign the assessment report. If an employee, then two signatures are necessary. Before reaching a decision, consider

Whether the person has auditing experience in the sector
Whether they are familiar with the technology and the processes
Whether they have experience of auditing against a standard

The choice rests on the enterprise itself. The lead assessor performs the appointed role.

The Lead Assessor?s Role

The Lead Assessor?s main job is reviewing an ESOS assessment prepared by others against the standard, and deciding whether it meets the requirements. They may also contribute towards it. Typically their role includes:

Checking the calculation for total energy consumption across the entire enterprise
Reviewing the process whereby the 90% areas of significant consumption were identified
Confirming that certifications are in place for all alternate routes to compliance chosen
Checking that the audit reports meet the minimum criteria laid down by the ESOS system

Note: A lead assessor may partly prepare the assessment themselves, or simply verify that others did it correctly.

In the former instance a lead assessor might

Determine energy use profiles
Identify savings opportunities
Calculate savings measures
Present audit findings
Determine future methodology
Define sampling methods
Develop audit timetables
Establish site visit programs
Assemble ESOS information pack

Core Enterprise Responsibilities

The enterprise cannot absolve itself from responsibility for good governance. Accordingly, it remains liable for

Ensuring compliance with ESOS requirements
Selecting and appointing the lead assessor
Drawing attention to previous audit work
Agreeing with what the lead assessor does
Requesting directors to sign the assessment

The Environment Agency does not provide assessment templates as it believes this reduces the administrative burden on the enterprises it serves.

Job & Staff Scheduling with FieldElite Mobile Service Management Software

Field Service Management (FSM) software systems are designed to enable you to manage your mobile workforce from a central point- and do away with the paperwork involved with the process. They connect your technicians on the ground (via app on their phones), to the staff at the head office- who have an interactive dashboard accessed through their browsers. The office team will have access to all the jobs that are to be handled by the company, simplifying the management process and taking away the risks that come with manual data entry. Here, we will walk you through a quick process of scheduling a job for your personnel with FieldElite.

Say you are a HVAC contractor, licensed, bonded and insured. You’ve made quite a name for yourself in the industry, and have a wide range of clients- in both residential and commercial establishments. Consequently, you also have a large workforce to attend to the different situations- from installing to repair and maintenance. One of your clients- let’s call them ABC Computer Supplies, has an issue with their HVAC unit- perhaps a pipe is leaking. It needs to be fixed, and ABC have booked an appointment.? Your goal here is to get one of your personnel to handle the task as soon as possible, and this field service scheduling software comes in handy.

There are two approaches that you can take:

1. Job Scheduling

From your Dashboard, on the left-hand side you will see the menu option. Clicking on Jobs, will take you to all jobs carried out by your company.

The filters will allow you to view different categories of jobs:

Complaint– This means that there was an issue with on ground during the task delivery, and the client lodged a complaint.
On hold– Here, different aspects can cause a job to be paused- like when spare parts or equipment required for repair jobs have been ordered, and one needs to wait for them to be shipped in from a different location.
Pending– This is basically your in-tray, a list of jobs that are to be carried out.
In Progress– The technicians are on the ground, attending to the client’s needs, and you’re getting routine updates from them.
Incomplete– Though the job had been assigned to the required technician, it was not completed in the set amount of time, thus requiring an additional visit to the site. Given that the FSM solution increases the first-time fix rate, cases of ?incomplete tasks? are reduced.
Complete– The task is successfully done and the customer has appended their e-signature, and now it can be invoiced.
Cancelled Invoice– The head office determines that a particular invoice shouldn’t be paid, and thus cancels it.

Our focus here is the pending tasks, so use this filter. ABC’s HVAC job will be among these. Clicking on its Job ID will open up the details of the task, with such an Update Job window:

This section contains all the information of the job- both past and present, which you can update in real-time. Any changes will be recorded by the system and can be viewed on the “Audit” tab.

As you can see here, the HVAC repair job is both “pending” and “urgent”. No one really likes sitting in an office that feels like an oven. Being the headquarters, it’s likely handles lots of foot traffic, and the damaged HVAC unit will make the working conditions really difficult. It’s best not to keep the client waiting, right?

So, head on over to the Supervisor and Workers section (on the same “Details” tab), and select the personnel suited for the task.

Set the time that the task will take for your technician, and once satisfied with the details of the job, click on Update. Voila! You’re done.

Immediately this happens, the worker received a notification on their app, telling them that they have been assigned the job.

From the app, the technician will be able to view the specifics of the HVAC job, including notes and attachments that you can add directly from your own dashboard, such as schematics of the building and reports from other technicians who installed the air conditioning system for the facility. You also get to add products that will be required for the task- like the pipe and panel mounted socket shown here. As the system also includes an inventory of the products used, their quantity and costs, you will be able to keep an accurate record of the supplies as they as are used.

As such, the field workers will not have to keep coming back to the central office to get documents and reports of new tasks, or walk around with bulky files. When they are carrying out the job, they will also be able to keep the staff at the office updated about its progress, through the chat feature on the mobile app, taking photos and adding notes as required.

2. Staff Scheduling

With this approach, the perspective is basically: ?So I have a couple of jobs- which of my employees has time to handle them?? The FSM allows you to optimise your productivity- by ensuring that you get the most out of the staff work hours, and avoid cases of jobs going into overtime.

Follow these steps:

Select ?Scheduler? from the left-hand side of the window. You will have a view of the workers of your company and how their day is planned out, and a summary of the unassigned jobs.

Here, you can tell whose busy, and who can have a new task assigned to them at the click of a button- which is far more effective than keeping on jotting down points in your diary or going through files of documents.

If the job has yet to be added to the system- like for the cases of new clients, simply click on the ?Add Job? button and key in its details.

2. Scroll down, you will see a list of unassigned jobs.

3. Next, click on the edit button under ?Actions?. This will take you to the same ?Update Job? window described in the first approach, in order to assign the preferred worker to the role.

This real-time dispatching avoids cases of your desk getting cluttered with paper sheets, and prevents duplicate entries as each job has its own ID and task details- from the scheduling to the invoicing. In this case, your HVAC technician will have access to the information needed right at the palm of their hand, to ensure that the task at ABC?s head office goes seamlessly. The optimised schedule will enable the task to be carried out faster- restoring normalcy to your client’s facility.? In case the client’s location is on the route that one of your technicians takes while heading home, you can take advantage of this by giving them the task towards the end of their working day- thus clearing more of your backlog, sorting out your client, and easing your technician?s worries about getting home late.

As you can see, the field service scheduling software enables you to easily and efficiently handle your workflow, avoid the mess that is associated with manual documentation and cases of your employees getting conflicting schedules and overlaps- which would strain them and dampen their morale. Streamlining your workflow and standardising operations ultimately results in increased customer satisfaction.

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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