How to Reduce Costs when Complying with SOX 404

Section 404 contains the most onerous and most costly requirements you’ll ever encounter in the Sarbanes-Oxley Act (SOX). In this article, we?ll take a closer look at the salient points of this contentious piece of legislation as it relates to IT. We?ll also explain why companies are encountering difficulties in complying with it.

Then as soon as we’ve tackled the main issues of this section and identify the pitfalls of compliance, we can then proceed with a discussion of what successful CIOs have done to eliminate those difficulties and consequently bring down their organisation’s IT compliance costs. From this post, you can glean insights that can help you plan a cost-effective way of achieving IT compliance with SOX.

SOX 404 in a nutshell

Section 404 of the Sarbanes-Oxley Act, entitled Management Assessment of Internal Controls, requires public companies covered by the Act to submit an annual report featuring an assessment of their company?s internal controls.

This ?internal control report? should state management’s responsibility in establishing/maintaining an adequate structure and a set of procedures for internal control over your company?s financial reporting processes. It should also contain an assessment of the effectiveness of those controls as of the end of your most recent fiscal year.

Because SOX also requires the public accounting firm that conducts your audit reports to attest to and report on your assessments, you can’t just make baseless claims regarding the effectiveness of your internal controls. As a matter of fact, you are mandated by both SEC and PCAOB to follow widely accepted control frameworks like COSO and COBIT. This framework will serve as a uniform guide for the internal controls you set up, the assessments you arrive at, and the attestation your external auditor reports on.

Why compliance of Section 404 is costly

Regardless which of the widely acceptable control frameworks you end up using, you will always be asked to document and test your controls. These activities can consume a considerable amount of man-hours and bring about additional expenses. Even the mere act of studying the control framework and figuring out how to align your current practices with it can be very tricky and can consume precious time; time that can be used for more productive endeavours.

Of course, there are exceptions. An organisation with highly centralised operations can experience relative ease and low costs while implementing SOX 404. But if your organisation follows a largely decentralised operation model, e.g. if you still make extensive use of spreadsheets in all your offices, then you’ll surely encounter many obstacles.

According to one survey conducted by FEI (Financial Executives International), an organisation that carried out a series of SOX-compliance-related surveys since the first year of SOX adoption, respondents with centralised operations enjoyed lower costs of compliance compared to those with decentralised operations. For example, in 2007, those with decentralised operations spent 30.1 % more for compliance than those with centralised operations.

The main reason for this disparity lies in the disorganised and complicated nature of spreadsheet systems.

Read why spreadsheets post a burden when complying with SOX and other regulations.

Unfortunately, a large number of companies still rely heavily on spreadsheets. Even those with expensive BI (Business Intelligence) systems still use spreadsheets as an ad-hoc tool for data processing and reporting.

Because compliance with Section 404 involves a significant amount of fixed costs, smaller companies tend to feel the impact more. This has been highlighted in the ?Final Report of the Advisory Committee on Smaller Public Companies? published on April 23, 2006. In that report, which can be downloaded from the official website of the US Securities and Exchange Commission, it was shown that:

  • Companies with over $5 Billion revenues spent only about 0.06% of revenues on Section 404 implementation
  • Companies with revenues between $1B – $4.9B spent about 0.16%
  • Companies with revenues between $500M – $999M spent about 0.27%
  • Companies with revenues between $100M – $499M spent about 0.53%
  • Companies with revenues less than $100M spent a whopping 2.55% on Section 404

Therefore, not only can you discern a relationship between the size of a company and the amount that the company ends up spending for SOX 404 relative to its revenues, but you can also clearly see that the unfavourable impact of Section 404 spending is considerably more pronounced in the smallest companies. Hence, the smaller the company is, the more crucial it is for that company to find ways that can bring down the costs of Section 404 implementation.

How to alleviate costs of section 404

If you recall the FEI survey mentioned earlier, it was shown that organisations with decentralised operations usually ended up spending more for SOX 404 implementation than those that had a more centralized model. Then in the ?Final Report of the Advisory Committee on Smaller Public Companies?, it was also shown that public companies with the smallest revenues suffered a similar fate.

Can we draw a line connecting those two? Does it simply mean that large spending on SOX affects two sets of companies, i.e., those that have decentralised operations and those that are small? Or can there be an even deeper implication? Might it not be possible that these two sets are actually one and the same?

From our experience, small companies are less inclined to spend on server based solutions compared to the big ones. As a result, it is within this group of small companies where you can find a proliferation of spreadsheet systems. In other words, small companies are more likely to follow a decentralised model. Spreadsheets were not designed to implement strict control features, so if you want to apply a control framework on a spreadsheet-based system, it won’t be easy.

For example, how are you going to conduct testing on every single spreadsheet cell that plays a role in financial reporting when the spreadsheets involved in the financial reporting process are distributed across different workstations in different offices in an organisation with a countrywide operation?

It’s really not a trivial problem.

Based on the FEI survey however, the big companies have already found a solution – employing a server-based system.

Typical server based systems, which of course espouse a centralised model, already come with built-in controls. If you need to modify or add more controls, then you can do so with relative ease because practically everything you need to do can be carried out in just one place.

For instance, if you need to implement high availability or perform backups, you can easily apply redundancy in a cost-effective way – e.g. through virtualisation – if you already have a server-based system. Aside from cost-savings in SOX 404 implementation, server-based systems also offer a host of other benefits. Click that link to learn more.

Not sure how to get started on a cost-effective IT compliance initiative for SOX? You might want to read our post How To Get Started With Your IT Compliance Efforts for SOX.?

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Outsourcing

Are you ready to outsource? Do you even need to outsource? We’ll help you answer those and other questions regarding outsourcing and your company.

Once we’ve determined that outsourcing will render your organisation more focused on your core competencies, more cost-effective, and more flexible, we’ll offer you the full spectrum of our services. Our specialists can assist you in every stage of the entire outsourcing life-cycle.

Starting from evaluating what can be outsourced, through finding the right outsourcing service provider, building the contract and agreements, getting everything in place, and managing the outsourcing relationship – we’ll be with you every step of the way.

Learn more about some of the outsourcing services we offer:

Outsourcing Contracts and Agreements

When an outsourcing project fails, both customer and service provider are quick to put the blame on the other party. But in most cases, the actual culprit was really just sitting there since day one – a poorly planned and implemented agreement.

We understand how costly and disruptive a failed outsourcing project can be for your business. That is why we put utmost attention to each contract and SLA (Service Level Agreement) that our customers enter into. This always reduces the likelihood of having unmet expectations, one of the major reasons why some outsourcing relationships fail.

We make sure that each agreement is fair, not only for our customers but also for the service providers themselves. Why? Because a disadvantaged provider will most likely end up delivering poor service as an offshoot of efforts to improve its profitability and ROI.

To accomplish this, we’ll thoroughly assess the infrastructure, resources, and expertise of your potential service provider to ensure they have the capability to meet your expectations. We’ll also make sure that their expectations are realistic and clear to you as well.

Here’s what you can expect from us when we start managing your outsourcing contracts and agreements:

  • A thorough assessment of your specific needs and the service provider’s profile to determine whether you have the right match before proceeding with any agreement.
  • Professional assistance when the time comes for you to discuss the scope of work, expected service levels, and when negotiating for appropriate pricing. We’ll also help you set up provisions for possible changes in the scope later on.
  • Expert counsel during drafting and finalisation of the contract and Service Level Agreements. Whenever applicable, we’ll help you propose penalties whenever service levels are not met and rewards when they are exceeded.
  • Regular reviews to determine whether everything agreed upon in the past, like pricing and service levels, are still realistic or competitive enough in view of current technological advancements and the prevailing social and economic environment.
  • Mediation expertise whenever the outsourcing project appears to be falling apart. We’ll work with you and the service provider to resolve conflicts and avoid the expensive exercise of having to terminate the contract. But if the best solution is to part ways, we’ll make sure you make an exit with the least disruption, missed opportunities and financial loss.

Application Outsourcing

I’m sure you’ve come to realise that to gain competitive advantage these days, you really need to invest in IT applications.

There are applications for enhancing your customer relationships, speeding up production, streamlining processes, advancing collaboration, protecting your systems from malware and many more. Selecting the right application, testing it, implementing it into your system, and then managing it can deviate resources which would have otherwise been used in other areas to build business value, increase profits, and enhance innovation.

Wouldn’t it be nice to unload yourself of the management processes which usually accompany IT applications? Actually, you can – through application outsourcing. Application outsourcing providers possess the expertise to either partially or fully assume responsibility of your IT applications.

Our job is to see to it that you link up with the provider who can best answer your needs. The overall proficiency of these providers spans both proprietary and opensource solutions, allowing them to cater to a wide range of preferences and budgetary limits. At the very least, they can provide professional support for well established applications.

If needed, they can develop applications for your organisation, taking charge of every step in the system development life-cycle: starting from system initiation, requirements analysis, through design, construction, acceptance and eventually to implementation.

Here are some of the benefits you can enjoy once we start managing your application outsourcing initiatives:

  • Freedom from time-consuming tasks such as installations, upgrades, configurations and repairs.
  • Reduced total cost of ownership (TCO).
  • 24/7 support from well-trained personnel. This can substantially cut downtimes caused by inexperienced troubleshooting.
  • The option to have your applications housed in more secure and reliable environments with much higher availability and much lower planned/unplanned downtimes.
  • Dedicated specialists who can focus on providing better regulatory compliance and risk mitigation initiatives.

Infrastructure Outsourcing

Keeping up with the competition nowadays usually requires technological advancements as well as the capability to manage and maintain the infrastructure that has to support them. These undertakings can suck your resources dry.

If you’re looking to reduce costs even while improving the performance of your networks, servers, databases, firewalls, desktops and mobile devices, you might want to consider IT infrastructure outsourcing among your top options. Infrastructure outsourcing service providers have the resources dedicated to a stable, secure, scalable and always available IT infrastructure.

Typical service provider facilities include data centrers equipped with high-speed networks, reliable power, dependable security, as well as provisions for upgrades, consolidation, disaster recovery, or even business continuity.

These providers employ specialists and staff who can manage and maintain all of these for you. While your provider juggles your core IT-related tasks, you can keep your eye on the ball and refocus on your company’s business goals.

Here are some of the benefits you can enjoy out of infrastructure outsourcing:

  • Freedom from time-consuming tasks such as installations, upgrades, configurations and repairs.
  • Since service providers, who are expected to have better horizontal and vertical scalability, will deal with the technological intricacies, your company’s strategic development initiatives can proceed unhampered.
  • Greatly reduced electricity expenses as a result of consolidation.
  • Easier, faster, cheaper, and more reliable disaster-recovery solutions through virtualisation.
  • Lesser risks of disruptions caused by power outages, cyber attacks, or Internet connection downtimes.

Business Process Outsourcing

With the sheer number of business processes your company has to attend to, it wouldn’t be surprising if you rarely have room to innovate.

Through business process outsourcing, we can free a considerable part of your financial and manpower resources which are currently focused on routine activities. With more resources to drive innovative initiatives, you’ll be able to accelerate production, improve customer service, enhance overall business value, and arrive at a stronger bottom line.

Some of the business processes that may be outsourced include data entry, finance and accounting, form processing, procurement, and HR, among others. If you’re interested in finding answers to the what, how, who, and where of BPO, specific to your organisation, we’ll be happy to enlighten you.

Here are some of the benefits you can enjoy once we start managing your BPO initiatives:

  • Professional guidance to ensure that your BPO undertakings will really result in substantial savings and significant improvements to your organisation’s business value.
  • Careful monitoring of service levels to ensure faster turnaround, accurate data, and high quality outputs.
  • Expert evaluation of information handling processes to guarantee full confidentiality.
  • Professional and unbiased management dedicated to establishing a strong, reliable, and fruitful relationship between you and your provider.
Virtualisation

Using an IT solution that can provide the fastest (but still reliable) disaster recovery process is essential for the success of any business continuity plan. Although virtualisation is still considered leading edge technology by many business continuity specialists, it definitely brings a promise that, once fulfilled, can result in the cheapest, fastest, and most comprehensive solution for business continuity.

One great advantage of virtualisation over traditional BC (Business Continuity) methods is the relatively cheaper cost needed to achieve a certain level of business continuity assurance. Thus, more companies will find it easier to reach their required minimum for BC assurance. By contrast, some BCPs (Business Continuity Plan) based on a physical environment require companies to invest more than what they are willing to in order to reach the same minimum level of assurance.

Virtual machines, which can already encapsulate your operating systems and their corresponding applications, can be transported as a file from one machine running a compatible hypervisor to another. This makes the business continuity tasks of backup, replication, and restoration simpler and faster.

As of 2008, about 54% of IT professionals in Europe were willing to implement virtualisation within a maximum of two years. Furthermore, the expected compound annual growth rate of installed virtualised servers from 2008 to 2012 is already pegged at 33%.

If you want your organisation to take advantage of the benefits of this revolutionary technology, we’d be more than willing to help you discover what it can do for you. Then once you decide to make that transition to virtualisation, we can guide you every step of the way.

  • As not all applications are suited for virtualisation (e.g. some are too demanding on I/O and memory access), we’ll start by reviewing your entire IT system to see which portions can be implemented on a virtualized environment.
  • Using virtualisation and replication, we can conduct disaster recovery tests using up-to-date data without interrupting operations in your main IT site. Running these tests will increase your team’s preparedness and will allow you to discover possible weak points.
  • Provide a simple but comprehensive protection and backup system that encapsulates not only data, but also system configurations and application installations. This kind of setup allows for faster and easier disaster recovery operations. Because of these same characteristics, you can enjoy zero downtime while performing scheduled maintenance operations.
  • Since virtual machines are hardware-independent and transparent to operating systems, we can help you run a mix of legacy and new systems as well as open source and proprietary systems, allowing for more flexibility in your BCP budgeting.

We can also assist you with the following:

Contact Us

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ESOS Guide for UK Manufacturers Available

The Engineering Employers’ Federation (EEF) is the UK’s largest sectoral structure. Its goal is to promote the interests of manufacturing, engineering and technology-based businesses in order to enhance their competitiveness.

EEF has positioned itself in London and Brussels in order to be in a position to lobby at EU and Westminster level. Part of its role is helping its members adapt to change and capitalise on it. When it discovered that a third of UK manufacturers must comply with ESOS (and 49% had not even heard of it) EEF decided it was time to publish a handbook for its members.

According to EEF’s head of climate and environment policy Gareth Stace, For the many manufacturers that have already taken significant steps to improve energy efficiency, ESOS can be viewed as a ?stock taking exercise?, ensuring that momentum is maintained and new measures are highlighted and taken when possible?.

He goes on to add that others that have not begun the process should view it as an ‘impetus’ to go head down and find the most cost-effective ways to slash energy costs. Ecovaro adds that they would also have the opportunity to reduce carbon emissions almost as a by-product.

Firms with more than 250 employees, over 250 million revenue or both must comply with ESOS across all UK sectors. In simplest terms, they must have conducted an energy audit by 5th December 2015, and logged their energy saving plan with the Environmental Agency that is Britain?s sustainability watchdog.

The Department of Energy & Climate Change (DEEC) that oversees it believes that large UK businesses are wasting ?2.8 billion a year on electricity they do not need. Clearly it makes sense to focus on larger targets; however EcoVaro believes those halfway to the threshold should voluntarily comply if cutting their energy bills by 25% sounds appealing.

We are able to assist with interpreting their energy audits. These are often a matter of installing sub-meters at distribution points, and reading these for a few representative months to establish a trend. Meters are inexpensive compared to electricity costs, and maintenance teams can install them during maintenance shutdowns.

Ecovaro helps these firms process the data into manageable summaries using cloud-based technology. This is on a pay-when-used basis, and hence considerably cheaper than acquiring the software, or appointing a consultant.

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