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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Competencies, Roles and Responsibilities of Lead Assessors

Any organisation that opts for energy audits, Display of Energy Certificates and Green Deal Assessments needs a lead assessor to review the chosen ESOS compliance routes. The Derivative provides that energy audits should be carried out independently by qualified and accredited experts. Additionally, these audits should be implemented as well as supervised by independent authorities under the national legislation.

Lead assessors undertake several roles in ESOS assessments. He or she is the one responsible to take the lead of the entire assessment team, prepare the plan, conduct the meetings and submit the formal report to governing authorities. Nevertheless, selecting an appropriate lead assessor is an important element that every organisation should carefully consider.

Competencies Requirements of Lead Assessors

Lead assessors should be knowledgeable enough with in-depth expertise in carrying out energy efficiency assessment. They should also possess foundational, functional and technical competencies to deliver the task effectively. Likewise, consider the assessors? sector experiences, familiarity with your business? technologies and properties, and accreditation with prescribed standards.

As you choose your lead assessor, contemplate on the skills and qualifications that would give your organisation benefits.

Roles and Responsibilities of Lead Assessors

The business organisation is responsible for the overall legal ESOS compliance. Moreover, here are some of the roles and responsibilities that lead assessors should assume in ESOS assessments.

The lead assessor agrees on the audit methodologies that the organisation would undergo in new audits. He or she agrees with the ESOS participant regarding the audit timetable, sampling approach and visits required. It is also the lead assessor?s role to identify the opportunities on energy saving and assist in calculating the cost savings from the measures taken. During the ESOS audits, the lead assessor determines the energy use profiles, presents the recommendations and reviews the entire assessment as a whole. Furthermore, he or she should maintain the evidence pack of the ESOS to uphold the audit’s credibility, its findings and recommendations.

Finding Lead Assessors

Energy and environment professionals would only be able to demonstrate their expertise as lead assessors upon registering in a professional body accredited by the Environment Agency. Any business that needs a lead assessor is advised to check on the EA?s website to see the details of approved registers.

Lead assessors can either be in-house experts or external professionals. However, they should be able to provide proof of membership as an approved register to take the role of a lead assessor. If the organisation has an internal lead assessor, the company should then take the final ESOS assessment to two board-level directors that would sign the formal report.

Indeed, the lead assessor is an organisation’s partner when it comes to delivering great results. With good professional conduct and excellent management of an assessment team, the lead assessor can help achieve breakthrough energy efficiency strategies. More than anything else, the organisation will benefit from maximum energy savings opportunities ahead. Thus, every qualified business enterprise should invest in finding the best lead assessor to guide them towards success.

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Benefits Realisation Frameworks – A Useful Handle

One of the greatest challenges of project management is maintaining top-down support in the face of fluctuating priorities. If you elect to take on the role yourself and are peppered by other priorities, it can be a challenge to exactly remember why you are changing things and what your goals are. Sometimes you may not even notice you have reached your goal.

The Benefits Realisation Chart-room

The Benefits Realisation Model is a framework on which to hang key elements of any project. These traditionally include the following, although yours may not necessarily be the same:

  • Definition of the project goal
  • Quantification of intended benefits
  • Project plan versus actual progress
  • How you know you reached your goal
  • Quantification of actual benefits

Another way of describing Benefits Realisation Frameworks is they answer four fundamental questions that every project manager should know by heart:

  • What am I going to do?
  • How am I going to do it?
  • When will I know it’s done?
  • What exactly did I achieve?

The Benefits Realisation Promise

An astounding number of projects fail to reach completion, or miss their targets. It’s not for nothing that the expression ?after the project failed the non-participants were awarded medals? is often used in project rooms. We’re not saying that it is a panacea for success. However it can alert you to warnings that your project is beginning to falter in terms of delivering the over-arching benefits that justify the effort.

When Projects Wander Off-Target

Pinning blame on participants is pointless when project goals are flawed. For example, the goals may be entirely savings-focused and not follow through on what to do with the windfall. At other times realisation targets may be in place, but nobody appointed to recycle the benefits back into the organisation. This is why a Benefits Realisation Framework needs to look beyond the project manager?s role.

Realisation Management in Practice

If the project framework does not look beyond the project manager?s role, then it is over when it reaches its own targets ? and can even run the risk of being an event that feeds entirely off itself. In order to avoid a project being a means to its own end, this first phase must culminate with handover to a benefits realisation custodian.

An example of this might be a project to centralise facilities that is justified in terms of labour savings. The project manager?s job is to build the structure. Someone else needs to rationalise the organisation.

In conclusion, the Benefits Realisation Framework is a useful way of ensuring a project does not only achieve its internal goals, but also remains a focus of management attention because of its extended, tangible benefits.

How Accenture Keeps Rolling Out Sustainability

Multinational management-consulting and technology-services company Accenture has a good eye for sniffing out new business, with 305,000 employees advancing its interests in more than 200 cities in 56 countries evidence. Last year, it netted US$30 billion profit that is a tidy sum of money in anybody?s books.

Accenture also practices what it preaches. This is maximum business efficiency within moral standards. It tracks its carbon emissions from its offices around the world. Being a technology services company it is unsurprising that it automated the process. Being management consultants it can drill down to finest detail in its search for continuous improvement.

As a forward-thinking company Accenture is committed to transplanting its business skills into other organizations, in order to drive higher performance and sustain greater profits in the long term. It works with clients across borders and industries to integrate sustainability into their business models, and find effective ways to lighten carbon footprints.

The City of Seattle in Washington is a case in point. Following a proud history of nature and energy conservation, it engaged Accenture in 2013 to help it reduce downtown power consumption by 25%. Other project members were Microsoft supplying software, the local power utility for technical advice, and a non-profit to set up a smart building program. The initiative uses cloud services to process the big data generated by a host of building management services, plus a multitude of sensors, controls and meters.

The project is vital for the City. It wants to continue expanding but needs to avoid another power plant polluting its skyline. At the time of writing, the pilot sites had proved successful and the program was rolling out. Seattle?s next challenge is to acquire 15% of its energy from renewable sources by 2020.

The smart building solutions Seattle trialled in five downtown buildings, had a further welcome spinoff; by reducing operating times, facility managers can look forward to extended equipment life and fewer maintenance downtimes. The green building philosophy is alive and well in the City of Seattle, driven both by necessity and vision.

It is a no longer as question of if – but when – other urban communities follow suit. EcoVaro believes it is time long due for individual companies to start enjoying lower energy costs plus the prospect of profitably trading carbon credits. The process begins with measuring what you have and identifying cost-effective savings.

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