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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How Volvo Dublin achieved Zero Landfill Status

The sprawling New River Valley Volvo plant in Dublin, Virginia slashed its electricity bill by 25% in a single year when it set its mind to this in 2009. It went on to become the first carbon-neutral factory in 2012 after replacing fossil energy with renewable power. Further efforts rewarded it with zero-landfill status in 2013. ecoVaro decided to investigate how it achieved this latest success.

Volvo Dublin?s anti-landfill project began when it identified, measured and evaluated all liquid and solid waste sources within the plant (i.e. before these left the works). This quantified data provided its environmental project team with a base from which to explore options for reusing, recycling and composting the discards.

Several decisions followed immediately. Volvo instructed its component suppliers to stop using cardboard boxes and foam rubber / Styrofoam as packaging, in favour of reusable shipping containers. This represented a collaborative saving that benefited both parties although this was just a forerunner of what followed.

Next, Volvo?s New River Valley truck assembly plant turned its attention to the paint shop. It developed methods to trap, reconstitute and reuse solvents that flushed paint lines, and recycle paint sludge to fire a cement kiln. The plant cafeteria did not escape attention either. The environment team made sure that all utensils, cups, containers and food waste generated were compostable at a facility on site.

The results of these simple, and in hindsight obvious decisions were remarkable. Every year since then Volvo has generated energy savings equivalent to 9,348 oil barrels or if you prefer 14,509 megawatts of electricity. Just imagine the benefits if every manufacturing facility did something similar everywhere around the world.

By 2012, the New River Valley Volvo Plant became the first U.S. facility to receive ISO 50001 energy-management status under a government-administered process. Further technology enhancements followed. These included solar hot water boilers and infrared heating throughout the 1.6 million square foot (148,644 square meter) plant, building automation systems that kept energy costs down, and listening to employees who were brim-full with good ideas.

The Volvo experience is by no means unique although it may have been ahead of the curve. General Motors has more than 106 landfill-free installations and Ford plans to reduce waste per vehicle by 40% between 2010 and 2016. These projects all began by measuring energy footprints throughout the process. ecoVaro provides a facility for you to do this too.

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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:

  1. Measure Total Energy Consumption in either kWh or energy spend in pounds sterling, and across the entire operation including buildings, industrial processes and transport.
  2. 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.
  1. 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
  1. 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.
  1. 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).
  1. 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.
  1. Notify the Environment Agency of Compliance within the deadline using the online notification system as soon as the enterprise believes is fully compliant.
  1. 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.

What Kanban can do for Call Centre Response Times

When a Toyota industrial engineer named Taiichi Ohno was investigating ways to optimise production material stocks in 1953, it struck him that supermarkets already had the key. Their customers purchased food and groceries on a just-in-time basis, because they trusted continuity of supply. This enabled stores to predict demand, and ensure their suppliers kept the shelves full.

The Kanban system that Taiichi Ohno implemented included a labelling system. His Kanban tickets recorded details of the factory order, the delivery destination, and the process intended for the materials. Since then, Ohno?s system has helped in many other applications, especially where customer demand may be unpredictable.

Optimising Workflow in Call Centres
Optimising workflow in call centres involves aiming to have an agent pick up an incoming call within a few rings and deal with it effectively. Were this to be the case we would truly have a just-in-time business, in which operators arrived and left their stations according to customer demand. For this to be possible, we would need to standardise performance across the call centre team. Moving optimistically in that direction we would should do these three things:

  • Make our call centre operation nimble
  • Reduce the average time to handle calls
  • Decide an average time to answer callers

When we have done that, we are in a position to apply these norms to fluctuating call frequencies, and introduce ?kanbanned? call centre operators.

Making Call Centre Operations Nimble
The best place to start is to ask the operators and support staff what they think. Back in the 1960?s Robert Townsend of Avis Cars famously said, ?ask the people ? they know where the wheels are squeaking? and that is as true as ever.

  1. Begin by asking technical support about downtime frequencies, duration, and causes. Given the cost of labour and frustrated callers, we should have the fastest and most reliable telecoms and computer equipment we can find.
  1. Then invest in training and retraining operators, and making sure the pop-up screens are valuable, valid, and useful. They cannot do their job without this information, and it must be at least as tech-savvy as their average callers are.
  1. Finally, spruce up the call centre with more than a lick of paint to awaken a sense of enthusiasm and pride. Find time for occasional team builds and fun during breaks. Tele-operators have a difficult job. Make theirs fun!

Reducing Average Time to Handle Calls
Average length of contact is probably our most important metric. We should beware of shortening this at the cost of quality of interaction. To calculate it, use this formula:

Total Work Time + Total Hold Time + Total Post Call Time

Divided By

Total Calls Handled in that Period

Share recordings of great calls that highlight how your best operators work. Encourage role-play during training sessions so people learn by doing. Publish your average call-handling time statistics. Encourage individual operators to track how they are doing against these numbers. Make sure your customer information is up to date. While they must confirm core data, limit this so your operators can get down to their job sooner.

Decide a Target Time to Answer Calls
You should know what is possible in a matter of a few weeks. Do not attempt to go too tight on this one. It is better to build in say 10% slack that you can always trim in future. Once you have decided this, you can implement your Kanban system.

Introducing Kanban in Your Call Centre Operation
Monitor your rate of incoming calls through your contact centre, and adjust your operator-demand metric on an ongoing basis. Use this to calculate your over / under demand factor. Every operator should know the value on this Kanban ticket. It will tell them whether to speed up a little, or slow down a bit so they deliver the effort the call rate demands. It will also advise the supervisor when to call up reserves.

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