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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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.

Business Turnaround Tip for a Successful MBO Turned Awry

When you acquire a company through an MBO, your hopes are always high. You know the business more than anyone else and you’ve got too much at stake to do a sloppy job. So how could things go wrong? Well sometimes they do. And if you don’t make a quick business turnaround, you could end up losing more than just your company.

If that management buyout was financed by a bank, then chances are you were required to invest a sizeable amount from your own pockets. I won’t be surprised if you even remortgaged your house for it.

Regardless of your source of funding, whether it was a bank, a venture capitalist or through a deferred consideration, the mere thought of losing your job and getting buried in enormous debt at the same time might be too much to bear. If you get too overwhelmed by your emotions and can’t think clearly, you’ll have to step out of the driver?s seat and have someone take over.

That someone can’t be a member of the management team that took part in the management buyout. Like you, he/she might be in panic mode as well. You need someone from the outside who has no emotional attachments to the company and hence can view the crisis from a clear perspective.

Here’s what’s needed:

Review and Plan

Take a closer look at all factors affecting your business: governance and organisational structures, employees, suppliers, systems and procedures, roles and responsibilities, etc. Identify potential risks and assess the likelihood of them affecting your business.

This will give a clearer picture of cause-and-effect relationships as well as the specific tasks on hand.

Thus, when it is time to draft a plan, you can do so from a well-informed standpoint. This will enable you to target specific areas of improvement and avoid pointless activities.

Assure all stakeholders

Once a watertight plan has been formulated, you will have to approach your stakeholders. They?ll need to know what your directions are. Once they’re all sold on the plan, you could implement our strategies unimpeded.

This is a very crucial part because a sceptical stakeholder can serve as a major stumbling block in our efforts to improve the situation. You need to convince your banks, sponsors, and investors in order to avoid additional financial obstacles. You need to convince your suppliers too. If they cut off or limit supply, you won’t be able to continue doing business.

Most of all, you need to persuade your staff and employees that the proposed major changes have to be carried out in order for the company to survive. You can’t run your operations without them on board.

Redesign and set up new systems and procedures

Any company requiring a turnaround will certainly have systems and procedures that are no longer working well in the current conditions and hence would require either major changes in key areas or a total revamp. You need to study personnel roles and responsibilities as well as systems and processes, including financial and IT systems, and supervise the implementation of necessary changes.

You will need to evaluate your existing IT architecture and determine how you can best maximise what you already have and propose what you think will work more efficiently for our proposed systems and procedures. Every piece of hardware or software recommended will take into consideration your present resources. There are many solutions out there, you just need to find the best fit.

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2015 ESOS Guidelines Chapter 3 to 5 ? The ESOS Assessment

ESOS operates in tandem with the ISO 50001 (Energy Management) system that encourages continual improvement in the efficient use of energy. Any UK enterprise qualifying for ESOS that has current ISO 50001 certification on the compliance date by an approved body (and that covers the entire UK corporate group) may present this as evidence of having completed its ESOS assessment. It does however still require board-level certification, following which it must notify the Environment Agency accordingly.

The Alternate ESOS Route

In the absence of an ISO 50001 energy management certificate addressing comprehensive energy use, a qualifying UK enterprise must:

Measure Total Energy Consumption in either kWh or energy spend in pounds sterling, and across the entire operation including buildings, industrial processes and transport.
Identify Areas of Significant Energy Consumption that account for at least 90% of the total. The balance falls into a de minimis group that is officially too trivial to merit consideration.

Consider Available Routes to Compliance. These could include ISO 500001 part-certification, display energy certificates, green deal assessments, ESOS compliant energy audits, self-audits and independent assessments

Do an Internal Review to make sure that you have covered every area of significant consumption. This is an important strategic step to avoid the possibility of failing to comply completely.

Appoint an Approved Lead Assessor who may be internal or external to your enterprise, but must have ESOS approval. This person confirms you have met all ESOS requirements (unless you have no de minimis exceptions).

Obtain Internal Certification by one of more board-level directors. They must certify they are satisfied with the veracity of the reports. They must also confirm that the enterprise is compliant with the scheme.

Notify the Environment Agency of Compliance within the deadline using the online notification system as soon as the enterprise believes is fully compliant.

Assemble your ESOS Evidential Pack and back it up in a safe place. Remember, it is your responsibility to provide proof of the above. Unearthing evidence a year later it not something to look forward to.

The ESOS assessment process is largely self-regulatory, although there are checks and balances in place including lead assessor and board-level certifications. As you work through what may seem to be a nuisance remember the primary objectives. These are saving money and reducing carbon emissions. Contact ecoVaro if we can assist in any way.