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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Excel Spreadsheet Conversion to SQL Reports

Spreadsheets are flexible, inexpensive and easy to use. They are especially handy when it comes to beating report submission deadlines or making impromptu data computations.

Unfortunately, organisations heavy reliance on spreadsheets have made these User Developed Applications (UDA) into high-risk office tools. Simple spreadsheet errors like leaving out a negative sign or a cut-and-paste mistake have already caused million-dollar discrepancies. Also, when a fraudulent employee enters into the picture, the risks become unimaginable.
Think TransAlta’s spreadsheet cut-and-paste glitch (the company later called this a ‘simple clerical error’) which caused the energy firm a whopping $24 million loss or Fidelity’s overstatement of its earnings owing to the omission of the minus sign on the spreadsheet of a $1.3 billion net capital loss.

Denizon can convert your Excel Spreadsheets to a web based SQL Server Reporting Services (SSRS). It does not import Excel data, rather it allows the creation and deployment of reports in a more efficient manner by querying the data.

So what is the problem with Spreadsheets?

Plagued with risk issues and vulnerable to fraud
Lacking in control features especially when copied, edited and emailed between many users
A burden to regulation compliance e.g. SOX (Sarbanes-Oxley)

Moreover:

Accidental copy-paste/Omission of a negative sign/Erroneous range selection
Incorrect data input or unintentional deletion of a character, cell, range, column, or row
Possibility of the user working on the wrong version
Prone to inconsistent company-wide reporting
Often ‘defenceless’ against unauthorised access

See Top 10 Disadvantages of Spreadsheets

What makes SQL Server Reporting Services better than Spreadsheets?

Free from spreadsheet risks & equipped with built-in controls that substantially reduce risks to data
Less prone to fraud
More suitable for regulatory compliance e.g. SOX
Designed for an agile business environment

Automatic consolidation eliminates errors and wasted time caused by tedious copy-pasting of data and linking of cells
Better collaboration capabilities allows team members to bring their heads together for planning, budgeting, and reporting even while on the go
Mobility support enables users to input data or retrieve information through their wireless mobile device

Superior sharing features ensures that everyone is exactly on the same page and viewing real-time information
Dashboards provide insightful information at-a-glance through KPIs, graphs, and various metrics
Drill-downs enable users to investigate unusual figures and gain a better understanding of the details that contribute to the big picture
Easy to learn interfaces allow your organisation to cope with fast personnel turnaround or Mergers & Acquisitions

Don’t know how to shift from Spreadsheets to SQL Server Reporting Services?

We’ve got the knowledge and expertise to assist you in:

Making a smooth and cost-efficient transition from risky spreadsheets to reliable reports
Designing and implementing SOX-compliant report-generating methods and procedures
Putting exposure to high-risk reporting methods a thing of the past

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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Green Business!

Carbon emissions reduction has evolved beyond simply good citizenship to being a business tool. Implementing ?green? initiatives is now a competitive weapon which defines real business opportunities and bottom line savings that can contribute significant financial value to the organisation while meeting demanding customer requirements for sustainable and low-carbon products.

Energy efficiency is a low cost resource for achieving carbon emissions reduction. Better energy efficiency simply translates to lesser carbon emissions and less energy usage which translates into saved costs.

Reduction of an organisations carbon footprint is each and everyone?s responsibility. Human activities are the key responsibility for the release of greenhouse gas emissions into the atmosphere. These include usage of electricity generated from fossil fuel, heating or driving.

At the corporate level, various measures can be instigated to increase energy efficiency. Some of these can be, having zone lighting with sensors to minimise unnecessary office lighting, timers on large IT equipment, promoting energy efficient behaviour in the office, asking staff to switch off and unplug appliances when not in use and minimising staff travel.
At the individual level; it is the small habits that count; cultivating the habit of switching off unnecessary lights, plugging out appliances that are not in use, using video conferencing or online chatting instead of having to travel to meetings, using public transport instead of taking a taxi/ personal car and using energy efficient cars.

All these initiatives assist organisations in their corporate social responsibility reports and play a role in sustainability rankings which is instrumental to customers who are increasingly considering sustainability rankings in investment decisions, while achieving the goal of cost reduction internally.