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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Risk Assessment

Risk assessment is a vital component in BC (Business Continuity) planning. Through risk assessment, your company may determine what vulnerabilities your assets possess. Not only that, you’ll also be able to quantify the loss of value of each asset against a specific threat. That way, you can rank them so that assets that are most likely to cripple your business when say a specific disaster strikes can be given top priority.

However, a poorly implemented risk assessment may also cost you unnecessary expenditures. Many risk assessors are too enthusiastic in pointing out risks that, at the end of the assessment, they tend to over-appraise even those having practically zero probability of ever occurring.

We can assure you of a realistic assessment of your assets’ risks and propose cost-effective countermeasures. These are the things we can do:

  • Identify your unsafe practices and propose the best alternatives.
  • Perform qualitative risk assessment if you want fast results and lesser interruptions on your operations.
  • Perform quantitative risk assessment if you want the most accurate depiction of your risks and the corresponding justifiable costs of each.
  • Conduct frequency and consequence analysis to identify unforeseen harmful events and determine their effects to various components of your organisation and its surroundings.

We can also assist you with the following:

How Bombardier Inc. scored a Bulls Eye

When travelling anywhere in the world on land, sea or air, chances are, you will travel courtesy of something made by aerospace and transportation company Bombardier based in Montreal, Canada. In 2009, it set itself the goal of carbon neutrality by 2020. In other words, it hoped to remove as much carbon dioxide from the atmosphere as it was putting in.

By 2012, Bombardier concluded it was not going to become carbon neutral by 2020 at its current rate of progress. It discounted purchasing carbon offsets because it believed it would serve its interests better by introducing new energy-saving products to market faster. That way, it would achieve its objectives vicariously through the decisions of its customers. But that was not all that forward-thinking Bombardier did. It also set itself the following inward-facing objectives:

  • Reduce carbon footprint through efficient use of energy and less emissions
  • Involve the Bombardier workforce to raise awareness of behaving responsibly
  • Implement sustainable initiatives to further reduce the company carbon footprint

Specific Examples

At its Wichita site, Bombardier (a) fitted a white roof and insulation reducing summer energy consumption by 40%, (b) added an energy recovery wheel to balance air circulation, and (c) introduced skylights with integrated controllers to lower energy consumption by lighting.

At Mirabel, it enhanced the flue-gas management system by adding a pressure differential damper.

At Belfast, Bombardier (a) optimised HVAC systems to reduce pressure on chilling and air-handling plants, (b) installed solar panels on the roof, and (c) obtained approval for a waste-to-energy plant that will convert 120,000 tonnes of non-recyclable waste material annually.

By the end of 2013, Bombardier had already beaten its immediate targets by:

  • Reducing energy consumption by 11% against 2009
  • Reducing greenhouse gas emission by 23% against 2009
  • Reducing water consumption by 6% against 2012

Future Plans

Bombardier will never stop striving to reach its goal of carbon neutrality by 2020. It has a number of other projects in the pipeline waiting for scarce resources to fund them. During 2014, it continued with energy efficient upgrades at its French, Hungarian, Polish, Swiss, and UK plants.

These include consumption monitoring systems, LEDs for workshop lighting, new heating systems, and outdoor energy-saving tower lighting. The monitoring is important because it helps Bombardier focus effort, and provides measured proof of progress.

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Integrated eCommerce – The right way to do extend your business online

With more people spending more time on the Web, now is the perfect time to start selling your products and services online. And if you think those people are only busy posting status updates on Facebook and Twitter but avoid all other websites, think again. Many are actually buying stuff online. E-commerce has never been bigger. In the UK, it was already worth 100 Billion two years ago.

Buyers are finding it more convenient to buy products and services online because they can do so from practically anywhere; even in the comfort of their homes. What’s more, they could browse through more choices at a fraction of the time they?d have spent doing the same thing in brick and mortar establishments.

So if your potential buyers are already out there, what’s stopping you from opening your virtual doors to greet them?

Antiquated e-Commerce

Now, before you start getting excited in setting up your own idea of an eCommerce-ready website, you might want to be aware of what a sound e-commerce investment entails these days. If all you’re thinking is a site that accepts orders and have someone enter those orders in your accounting system, then you’ve got it all wrong.

You’re never going to get good returns on your investment that way. While you’re opening doors for new income streams, you’re also introducing additional costs and sophistication for processes that are highly susceptible to errors, inconsistencies, delays, and, eventually, client dissatisfaction.

Doing it right with integrated e-Commerce

To compete with others who are also offering the same products and services as yours, you need to ensure complete customer satisfaction. The best way to achieve this is to employ integrated e-commerce. This is an e-commerce system that combines your payment system, accounting, ERP, CRM, inventory management, analytics, and others into a cohesive, synchronised environment.

The idea is to do away with majority of your manual tasks in order to achieve fast, efficient, accurate, and secure transactions and other related processes.

eCommerce integration will allow you to do business 24/7 without requiring any of your staff to render the same number of hours. That means, your company continues to operate and earn even while all of you are fast sleep.

Then when you’re up, you can view reports telling you what transpired overnight, over the weekend or over any specified period of time. The information you obtain can help you make well-informed decisions and act on issues much quicker.

And because your business is on the Web, you can serve customers and obtain new ones from geographical locations far from where your office or store is actually located. If you want, you can even gain customers from halfway around the world.

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  • (+44)(0)20-7193-9751 – UK

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