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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FUJIFILM Cracks the Energy Code

FUJIFILM was in trouble at its Dayton, Tennessee plant in 2008 where it produced a variety of speciality chemicals for industrial use. Compressed-air breakdowns were having knock-on effects. The company decided it was time to measure what was happening and solve the problem. It hoped to improve reliability, cut down maintenance, and eliminate relying on nitrogen for back-up (unless the materials were flammable).

The company tentatively identified three root causes. These were (a) insufficient system knowledge within maintenance, (b) weak spare part supply chain, and (c) generic imbalances including overstated demand and underutilised supply. The maintenance manager asked the U.S. Department of Energy to assist with a comprehensive audit of the compressed air system.

The team began on the demand side by attaching flow meters to each of several compressors for five days. They noticed that – while the equipment was set to deliver 120 psi actual delivery was 75% of this or less. They found that demand was cyclical depending on the production phase. Most importantly, they determined that only one compressor would be necessary once they eliminated the leaks in the system and upgraded short-term storage capacity.

The project team formulated a three-stage plan. Their first step would be to increase storage capacity to accommodate peak demand; the second would be to fix the leaks, and the third to source a larger compressor and associated gear from a sister plant the parent company was phasing out. Viewed overall, this provided four specific goals.

  • Improve reliability with greater redundancy
  • Bring down system maintenance costs
  • Cut down plant energy consumption
  • Eliminate nitrogen as a fall-back resource

They reconfigured the equipment in terms of lowest practical maintenance cost, and moved the redundant compressors to stations where they could easily couple as back-ups. Then they implemented an online leak detection and repair program. Finally, they set the replacement compressor to 98 psi, after they determined this delivered the optimum balance between productivity and operating cost.

Since 2008, FUJIFILM has saved 1.2 million kilowatt hours of energy while virtually eliminating compressor system breakdowns. The single compressor is operating at relatively low pressure with attendant benefits to other equipment. It is worth noting that the key to the door was measuring compressed air flow at various points in the system.

ecoVaro specialises in analysing data like this on any energy type.?

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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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Firewalls

There are two main reasons why some companies are hesitant to plug into the Internet.

  1. They know they’ll be exposing their company data to outside attacks from malicious individuals and malware.
  2. They fear their employees might get too many distractions: games, porn, chats, videos, and even social networking sites.

One vital component for your overall security strategy against such concerns? A firewall.

A firewall can block unauthorised access to certain Internet services from inside your organisation as well as prevent unauthenticated access from the outside. It is also used to monitor users’ activities while they were online.

In an enterprise setting, one may expect a collection of firewalls either for providing layered protection or segmenting off different units in the organisation. Some areas only need a standard line of defence while others require more restrictions. As such, certain firewalls may have different configurations compared to others.

Naturally, the more intricate an organisation’s defence requirements get, the more complex the task of monitoring, testing and configuring the firewalls becomes. That’s why we’re here to help.

  • We’ll evaluate your network as well as the security requirements of each department under your organisation to determine which firewall architecture is most suitable.
  • To achieve maximum efficiency, we’ll point out where each firewall should be positioned.
  • We’ll work with your key personnel to make sure all firewall configurations are set and optimised with your business rules in mind.
  • If a large number of firewalls are required, we’ll help you set up a firewall configuration management system.
  • Firewalls should be regularly tested and assessed to ensure they are in line with the organisation’s security policies. We’ll perform these routine tasks as well.

Firewalls aren’t very good at defending against sophisticated viruses. There are much better solutions for malware-related vulnerabilities, and we can help you in that regard too.

Other defences we’re capable of putting up include:

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