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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2015 ESOS Guidelines Chapter 1 ? Who Qualifies

The base criteria are any UK undertaking that employs more than 250 people and/or has a turnover in excess of ?50 million and/or has a balance sheet total greater than ?43 million. There is little point in attempting to separate off high polluting areas. If one corporate group qualifies for ESOS, then all the others are obligated to take part too. The sterling equivalents of ?38,937,777 and ?33,486,489 were set on 31 December 2014 and apply to the first compliance period.

Representatives of Overseas Entities

UK registered branches of foreign entities are treated as if fully UK owned. They also have to sign up if any overseas corporate element meets the threshold no matter where in the world. The deciding factor is common ownership throughout the ESOS system. ecoVaro appreciates this. We have seen European companies dumping pollution in under-regulated countries for far too long.

Generic Undertakings that Could Comply

The common factor is energy consumption and the organisation’s type of work is irrelevant. The Environmental Agency has provided the following generic checklist of undertakings that could qualify:

Limited Companies	Public Companies	Trusts
Partnerships	Private Equity Companies	Limited Liability Partnerships
Unincorporated Associations	Not-for-Profit Bodies	Universities (Per Funding)

Organisations Close to Thresholds

Organisations that come close to, but do not quite meet the qualification threshold should cast their minds back to previous accounting periods, because ESOS considers current and previous years. The exact wording in the regulations states:

?Where, in any accounting period, an undertaking is a large undertaking (or a small or medium undertaking, as the case may be), it retains that status until it falls within the definition of a small or medium undertaking (or a large undertaking, as the case may be) for two consecutive accounting periods.?

Considering the ?50,000 penalty for not completing an assessment or making a false or misleading statement, it makes good sense for close misses to comply.

Joint Ventures and Participative Undertakings

If one element of a UK group qualifies for ESOS, then the others must follow suit with the highest one carrying responsibility. Franchisees are independent undertakings although they may collectively agree to participate. If trusts receive energy from a third party that must do an ESOS, then so must they. Private equity firms and private finance initiatives receive the same treatment as other enterprises. De-aggregations must be in writing following which separated ESOS accountability applies.

Strategy and Portfolio Management

A well planned strategy is the necessary bridge between brilliant leadership and excellent execution. Without it, your entire organisation cannot hope to respond quickly and effectively to challenges and changes within the landscape on which it operates.

Strategic planning involves identifying objectives, understanding what resources are needed to attain them, and then allocating the resources to the appropriate units to ensure they are used optimally towards the achievement of desired objectives. Among the end results which can be reflected by your team members are:

Deeper understanding of the competitive environment;
Snappy execution of plans;
Faster, more aligned actions; and
More intelligent and apt responses against strategic moves of the competition.

We understand the need to institute strategic management in such a way that your organisation can easily adapt to unforeseen developments. As such, all our solutions are formulated to make your organisation not only well-guided but also as dynamic as possible.

Strategy Formulation

Before you can proceed to map out any strategy for your company, you’ll have to study your company’s current environment. This will help you determine what courses of action should be taken to be able to navigate through such environment on your way to the end goal.

If you’re not a full time strategist, such a task can either be very daunting or deceivingly easy… the former can prevent your team from getting started, while the latter can lead your team astray.

Ideally, strategy formulation should be carried out as quickly and as efficiently as possible so you can move on to implementation before the competition can react. Our methods can enable your leaders to hit the ground running each time they set out on a strategic plan.

How?

We can assist in accurately applying strategic tools like SWOT and Gap analysis, then help integrate the results into an effective strategic plan.
We’ll train your team how to carry out effective research techniques so that the information they gather will really be what we need. This is because the tools mentioned earlier can only work effectively if the inputs were picked intelligently. Of course, if you want the entire process expedited, we can also conduct the research ourselves.
We’ll establish best practices for top-down, bottom-up, and collaborative strategic management processes. We’ll even show you how to organise and hold meetings where team members are constantly engaged and in-sync, so action plans can be developed and relayed fast.
We’ll see to it that strategies for all functional departments (such as IT management, supply-chain, HR, marketing, and legal) are in line with your business strategies, which should in, turn be aligned with your overall corporate strategy.

Strategy Evaluation

Your strategies have to be periodically assessed if you want to determine whether they are attuned to variations affecting your organisation. These changes may include new technologies, emerging competitors, new opportunities, as well as unexpected developments in the economic environment and political climate.

While no time limit is imposed for the build-up of resources vital to the attainment of a specific objective, the window of opportunity can shut on you before you can start amassing such resources. Given this possibility, it is important for your strategies to undergo evaluation processes that will determine whether you should pursue them or not.

Using only the most reliable evaluation techniques, we’ll help you establish whether:

Your strategies will place your company in a position that will give it competitive advantage or will erode whatever advantage the competition already has;
Your strategies are consistent with the landscape on which your company currently traverses;
They are realistic enough in relation to the resources you have on hand;
The associated risks have all been identified and the appropriate control measures have already been put in place;
The time frames for their full realisation are both realistic and acceptable.

Portfolio Management

In today’s highly competitive market, many of the more successful enterprises are driven by project-based systems.

Now, there’s always a tendency for project managers to become overenthusiastic and to come up with a number of projects that can’t be sustained by available resources. If your project-based company frequently runs out of resources, then either you just have too many projects running or too much is being allocated to a select few.

In both instances, the problem does not necessarily lie on the individual project managers themselves. Rather, what is needed is the ability to have full control over existing projects and investments.

Your leadership should be able to rank projects in terms of their impact to your organisation’s growth, positioning, and profitability. This will give you sufficient information when deciding which projects to pursue, prioritise, or shut down. These are the benefits you’ll gain from our services:

A vivid presentation of the big picture. Only when you can step back from all the detail and see the interplay of investments and resources will you be able to make wise decisions regarding how and where to position them.
The ability to distinguish between projects with the highest potentials and those that are outdated.
Access to expertise that will help you distribute your present IT infrastructure, human resources, financial resources, and facilities across running projects to obtain the biggest benefits for all stakeholders.

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Benefits of Integrating IoT and Field Service

Owing to the complexity of its definition, many people loosely use the phrase Internet of Things (IoT) without having a solid grasp of its true meaning. A majority in this category take IoT to be nothing more than the automation of home gadgets, where the internet is used to interconnect computing components embedded in everyday devices.

Granted, the whole idea of IoT got its roots from the home setting. Nevertheless, IoT has outgrown that spectrum and has since penetrated into almost every area of business and industry. By employing IoT, you can literally take full control of everything in your business using a single device. From assigning tasks to monitoring security, managing bills to tracking time, IoT has revolutionized the way business is done.

Interestingly, not so long ago, most technology experts limited their forecasts to machine-to-machine (M2M) integration and Augmented Reality (AR), which also, admittedly, hit the technology industry with an admirable suave. Back then, it could have been laughable for anyone to have suggested that IoT would be so commanding in almost every industry, including real estate, medicine, automobile, and more.

It’s not for nothing, therefore, that the field service industry has also embraced IoT, integrating it in the daily running of business activities, including tracking machine diagnostics, detecting breakdowns, and assigning field engineers to attend to customer needs.

How the Field Service Industry is Benefiting from IoT

Machine uptime has remained an ongoing concern for many customers. In the traditional approach, whenever a machine breaks down, the customer alerts the service provider and then the field service manager checks to see if there is any field engineer available for a new task. Once an engineer has been identified, he?s then dispatched to the site. This worked, but it resulted in an extended machine downtime, a terrible experience for customers.

Thanks to IoT, things are now happening differently.

IoT is now integrating machines to a central communications centre, where all alerts and status updates are sent. The notifications are instant. The field service manager, therefore, gets to learn of the status of machines at the exact time of status change. An engineer who?s not engaged would then be immediately assigned to undertake any needed servicing or repair.

By employing IoT, the service provider receives timely reports relating to diagnostics, machine uptime, part failures, and more. The field manager can, as a result, foretell and forestall any possible downtime.

How has this been helpful?

Before giving a definite answer to that question, it’s crucial to note that more than half of all field service organizations now employ IoT in their Asset Management Systems and Field Service Management. And to answer the question, all the organizations that have the two systems integrated using IoT experience twice as much efficiency as those that don’t, states an Aberdeen Group report. As you already know, improved efficiency results in a corresponding upshot in customer satisfaction.

Apps Making a Difference in IoT-Field Service

The integration of IoT into almost every aspect of business prompted the design and development of different applications to link computing devices. Since the advent of IoT, the software development for the technology has come of age. Powerful and lightweight apps that don simple yet beautiful user interfaces are now readily available at affordable price tags.

A good example of such an App is ecoVaro by Denizon.

ecoVaro not only helps businesses to monitor energy and other relevant environmental data such as Electricity, Gas, Water, Oil, Carbon, Temperature, Humidity, Solar Power, and more, but also provides analytics and comprehensive yet easy to understand reports. The data received from devices such as meters is converted into useful information that’s then presented in figures and graphs, thus allowing you to make decisions based on laid down controls.

The focus of the app is to instantly alert service engineers to go on site to fix issues.

With ecoVaro, field service engineers no longer have to return to the office to get new instructions. Also, customers don’t have to manually fire alerts to the service provider whenever something isn’t working correctly. By employing the latest in IoT, ecoVaro sends notifications to field service managers and engineers about respective customers that need support.

How ecoVaro Helps

Best-in-class companies aren’t ready to compromise on customer satisfaction. Therefore, every available avenue is used to address customer concerns with the deserved agility. By using IoT, ecoVaro makes it possible for field service providers to foresee and foreclose any possible breakdowns.

The inter-connectivity among the devices and the central communications centre results in increased revenue and improved interactivity between the system and the field engineers. This results in greater efficiency and lower downtime, which translates into improved productivity, accountability, and customer satisfaction, as well as creating a platform for a possible expansion of your customer base.

ecoVaro isn’t just about failed machines and fixes. It also provides diagnostics about connected systems and devices. With this, the diagnostics centre receives system reports in a timely manner, allowing for ease of planning and despatch of field officers where necessary.

Clearly, but using the right application, IoT can transform your business into an excellently performing field service company.