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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EU Energy Efficiency Directive & UK?s ESOS

In 2012 the European Union passed its EU Energy Efficiency Directive (EED) into law. This aims to reduce overall energy consumption by 20% by 2020. It placed an obligation on member states to pass back-to-back local legislation by June 2014.

EED Guidelines

The EED provides specific guidelines it expects member nations to address. The list is long and here are a few excerpts from it:

  • Large companies must use energy audits to identify ways to cut their energy consumption
  • Small and medium companies must be incentivised to voluntarily take similar steps
  • Public sector bodies must purchase energy-efficient buildings, products and services
  • Private energy-consumers must be empowered with information to help manage demand
  • Energy distributors / resellers must cut their own consumption by 1.5% annually
  • Legislators are free to substitute green building technology e.g. through better insulation
  • Every year, European governments must audit 3% of the buildings they own

Definition of Energy Audit

An energy-consumption audit is a question of measuring demand throughout a supply grid, with particular attention to individual modules and high demand equipment. While this could be an exercise repeated every four years to satisfy ESOS, it makes more sense to incorporate it into the monthly energy billing cycle.

Because energy use is not consistent but varies according to production cycle, this can produce reams of printouts designed to frustrate busy managers. ecoVaro offers an inexpensive, cloud-based analytic service that effortlessly accepts client data and returns it in the form of high-level graphic summaries.

Potential ESOS Beneficiaries

As many as 9,000 UK companies are obligated to do energy audits because they employ more than 250 employees, have a balance sheet total over ?36.5m or an annual turnover in excess of ?42m. Any smaller enterprise that finds energy a significant input cost, should also consider enlisting Ecovaro to help it to:

  • Obtain a better understanding of the energy side of their business
  • Achieve energy savings and share in a estimated ?3bn bonanza to 2030
  • Reduce carbon emissions to help meet their CRC commitments

More About ecoVaro

We offer web-based energy management software that helps you measure and manage energy costs. This strips data from your meters and generates personalised reports on a dashboard you control. This information helps you accurately zoom in on worthwhile opportunities. With Ecovaro on your side, ESOS truly becomes an Energy Saving OPPORTUNITY Scheme.

How DevOps Could Change Your Business

Henry Ford turned the U.S. auto industry on its head when he introduced the idea of prefabricating components at remote sites, and then putting them together on a production line. Despite many industries following suit, software lagged behind until 2008, when Andrew Clay Shafer and Patrick Debois told the Agile Conference there was a better way to develop code:
– Write the Code
– Test the Code
– Use the Code
– Evaluate, Schedule for Next Review

The term ?DevOps? is short for Development and Operations. It first appeared in Belgium, where developers refined Shafer and Depois? ideas. Since then, DevOps became a counter movement against the belief that software development is a linear process and has largely overwhelmed it.

DevOps – A Better Way

DevOps emerged at an exciting time in the IT industry, with new technology benefiting from a faster internet. However, the 2008 world recession was also beginning to bite. Developers scampered to lower their human resource costs and get to market sooner.

The DevOps method enabled them to colloborate across organizational boundaries and work together to write, quality assure and performance test each piece of code produced in parallel.
DevOps? greater time-efficiency got them to market sooner and helped them steal a march on the competition.

There are many advantages to DevOps when we work in this collaborative way. Cooperation improves relationships between developers, quality assurers and end users. This helps ensure a better understanding of the other drivers and a more time-effective product.

Summary of DevOps Objectives

DevOps spans the entire delivery pipeline, and increases the frequency with which progress is reviewed, and updates are deployed. The benefits of this include:

? Faster time to market and implementation

? Lower failure rate of new releases

? Shortened lead time for bug fixes and updates

The Psycho-Social Implications of DevOps

DevOps drills through organization borders and traditional work roles. Participants must welcome change and take on board new skills. Its interdepartmental approach requires closer collaboration across structural boundaries and greater focus on overarching business goals.

Outsourcing the detail to freelancers on the Internet adds a further layer of opportunity. Cultures and time zones vary, requiring advanced project management skills. Although cloud-based project management software provides adequate tools, it needs an astute mind to build teams that are never going to meet.

The DevOps movement is thus primarily a culture changer, where parties to a project accept the good intentions of their collaborators, while perhaps tactfully proposing alternatives. There is more to accepting a culture than using a new tool. We have to blend different ways of thinking together. We conclude by discussing three different methods to achieve this.

Three Ways to Deploy DevOps in your?Organisation

If you foresee regular DevOps-based projects, consider running your entire organisation through an awareness program to redirect thinking. This will help non-participants understand why DevOps members may be ?off limits? when they are occupied with project work. Outsourcing tasks to contracting freelancers can mitigate this effect.

There are three implementation models associated with DevOps although these are not mutually exclusive.

? Use systems thinking. Adopt DevOps as company culture and apply it to every change regardless of whether the process is digital, or not

? Drive the process via increased understanding and feedback from key receivers. Allow this to auto-generate participative DevOps projects

? Adopt a continuous improvement culture. DevOps is not only for mega upgrades. Feedback between role players is paramount for success everywhere we go.

You can use the DevOps concept everywhere you go and whenever you need a bridge to better understanding of new ideas. We diminish DevOps when we restrict its usefulness to the vital role it plays in software development. The philosophy behind it belongs in every business.

Large scale corporate transformation

Large scale corporate transformation are the necessary actions required to increase performance in an organisation. It leads to greater performance results and greater organisational growth. It is a lasting change and can range from getting new leaders to combining the functions of different departments. It can also involve the introduction of a new phase in the life of an organisation. Large scale corporate transformation can be measured using three variables. The first variable involves determining how deep the change penetrates to all levels of the organisation. The second variable measures how entrenched it becomes in the organisation while the third measure determines the percentage of the organisation covered in the change.

Corporate transformation is essential for a company that seeks to have a greater impact and a longer life in its business sector. The process requires time and resources. The whole establishment needs to support it for success. Not only does the top management need to back it, but stockholders and staff members also need to buy the idea. This is because when the process of corporate transformation hits a barrier, it will take the entire organisation to keep it on course and complete the process. Without the support of everyone, most organisations will not complete the process.

Business transformation in recent times has begun to combine finance, HR and IT departments into one functioning piece of an organisation. This has resulted in leaner, faster, and more efficient corporate entities that produce high results and has a greater impact in its overall functioning. These three key departments are the backbone of any organisation, and the combination of the three creates an efficient organisation that translates into high performance results.

One crucial aspect of large scale corporate transformation is IT transformation, which entails the entire overhaul of any organisation’s technology systems. It adopts a more efficient platform that enhances its overall operation. IT transformation involves the use of Service Oriented Architecture (SOA) and open systems. This process is the revamping of the existing technology used to support the organisation and is critical for aligning the business functions to the mission of the organization. It touches on the current hardware and software and how they can best be improved upon for greater results. This process is necessary in the entire business transformation.

The question that needs to be addressed is how any organisation can make this process successful. First, it requires the understanding that it is not just a goal to be achieved, but a new way of thinking embraced by the entire organisation. Secondly, the leadership in place needs to be fully involved and dedicated to the process and to realise that it takes time and effort to complete such a mission. There also needs to be flexibility and adaptability in order to learn from mistakes and keep moving forward. Constant communication is also critical to ensure that everyone involved understands the current stage and the next steps to be done. Change is the only constant and is necessary for progress and success.

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