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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Without Desktop Virtualisation, you can’t attain True Business Continuity

Even if you’ve invested on virtualisation, off-site backup, redundancy, data replication, and other related technologies, I?m willing to bet your BC/DR program still lacks an important ingredient. I bet you’ve forgotten about your end users and their desktops.

Picture this. A major disaster strikes your city and brings your entire main site down. No problem. You’ve got all your data backed up on another site. You just need to connect to it and voila! you’ll be back up and running in no time.

Really?

Do you have PCs ready for your employees to use? Do those machines already have the necessary applications for working on your data? If you still have to install them, then that’s going to take a lot of precious time. When your users get a hold of those machines, will they be facing exactly the same interface that they’ve been used to?

If not, more time will be wasted as they try to familiarise themselves. By the time you’re able to declare ?business as usual?, you’ll have lost customer confidence (or even customers themselves), missed business opportunities, and dropped potential earnings.

That’s not going to happen with desktop virtualisation.

The beauty of?virtualisation

Virtualisation in general is a vital component in modern Business Continuity/Disaster Recovery strategies. For instance, by creating multiple copies of virtualised disks and implementing disk redundancy, your operations can continue even if a disk breaks down. Better yet, if you put copies on separate physical servers, then you can likewise continue even if a physical server breaks down.

You can take an even greater step by placing copies of those disks on an entirely separate geographical location so that if a disaster brings your entire main site down, you can still gain access to your data from the other site.

Because you’re essentially just dealing with files and not physical hardware, virtualisation makes the implementation of redundancy less costly, less tedious, greener, and more effective.

But virtualisation, when used for BC/DR, is mostly focused on the server side. As we’ve pointed out earlier in the article, server side BC/DR efforts are not enough. A significant share of business operations are also dependent on the client side.

Desktop virtualisation (DV) is very similar to server virtualisation. It comes with nearly the same kind of benefits too. That means, a virtualised desktop can be copied just like ordinary files. If you have a copy of a desktop, then you can easily use that if the active copy is destroyed.

In fact, if the PC on which the desktop is running becomes incapacitated, you can simply move to another machine, stream or install a copy of the virtualised desktop there, and get back into the action right away. If all your PCs are incapacitated after a disaster, rapid provisioning of your desktops will keep customers and stakeholders from waiting.

In addition to that, DV will enable your user interface to look like the one you had on your previous PC. This particular feature is actually very important to end users. You see, users normally have their own way of organising things on their desktops. The moment you put them in front of a desktop not their own, even if it has the same OS and the same set of applications, they?ll feel disoriented and won’t be able to perform optimally.

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Disaster Recovery

Because information technology is now integrated in most businesses, a business continuity plan (BCP) cannot be complete without a corresponding disaster recovery plan (DRP). While a BCP encompasses everything needed – personnel, facilities, communications, processes and IT infrastructure – for a continuous delivery of products and services, a DRP is more focused on the IT aspects of the plan.

If you’re still not sure how big an impact loss of data can have, it’s time you pondered on the survival statistics of companies that incurred data losses after getting hit by a major disaster: 46% never recovered and 51% eventually folded after only two years.

Realising how damaging data loss can be to their entire business, most large enterprises allocate no less than 2% of their IT budget to disaster recovery planning. Those with more sensitive data apportion twice more than that.

A sound disaster recovery plan is hinged on the principles of business continuity. As such, our DRP (Disaster Recovery Plan) blueprints are aimed at getting your IT system up and running in no time. Here’s what we can do for you:

  • Since the number one turn-off against BCPs and DRPs are their price tags, we’ll make a thorough and realistic assessment of possible risks to determine what specific methods need to be applied to your organisation and make sure you don’t spend more than you should.
  • Provide an option for virtualisation to enjoy substantial savings on disaster recovery costs.
  • Provide various backup options and suggest schedules and practices most suitable for your daily transactions.
  • Offer data replication to help you achieve business continuity with the shortest allowable downtime.
  • Refer to your overall BCP to determine your organisation’s critical functions, services, and products as well as their respective priority rankings to know what corresponding IT processes need to be in place first.
  • Implement IT Security to your system to reduce the risks associated with malware and hackers.
  • Introduce best practices to make future disaster recovery efforts as seamless as possible.

We can also assist you with the following:

What is Servitisation?

In the current generation, innovation has transformed industries, businesses, economies, and livelihoods. Those who’ve accepted to embrace the changes have prospered and remained afloat and relevant in their respective industries.?

However, failure to embrace change has seen companies like Blockbuster pushed out of business by more innovative and technology-oriented companies like Netflix.?

What does this tell you?

That the only way to stay in business, despite the many challenges your business could be facing, is to remain alert to the dynamic demands of customers, many of which are dictated by technological advancements.?

So, if you’re a manufacturer and you’re keen on diving deeper into technology to stay on top of the game and beat your competition, you must also be expectant of the fast-approaching servitisation-centred economy. Companies like Rolls Royce that have already embraced servitisation are making great gains in their areas of expertise.?

What is Servitisation?

Servitisation can be defined as the transformation of a manufacturing firm from the mere offering of products to the market to providing innovative and invaluable services alongside their products. By so doing, the sale becomes an ongoing engagement and not a one-off event. Cranfield University professors call it “the innovation of an organisation’s capabilities and processes to better create mutual value through a shift from selling a product to selling product-service systems.”?

As foreign as it may seem for some professionals, servitisation has been a need that, though not embraced, its demand remains evident. Nonetheless, firms have hesitated to implement it. Shifting from manufacturing products only to incorporating product-centric services alongside the products is not a walk in the park. It boils down to completely changing the company’s entire structure and processes.

All the same, change is never comfortable, and that’s why it’s always best to focus on the positive for motivation.

Servitisation Case Study

Some manufacturing firms have already embraced servitisation, and they’re reaping big from it. They’ve understood the benefits of offering more value to customers at less cost. What Rolls Royce is doing currently with its “power-by-the-hour” program is a good example of servitisation.

Instead of selling Aero Engines and letting customers take charge of maintenance and uptime, Rolls-Royce now offers a full package that includes a product and relevant services.?

Essentially, what the company is creating is an intimate and long-term relationship with its customers.

The total care package by Rolls Royce means it’s essentially renting out its engines to customers and monitoring data for potential maintenance needs. The plan guarantees that maintenance is only done when necessary and avoidable damage detected in good time. As a result, there is a clear reduction in the overall cost.

Initially, Rolls Royce would make money by basically selling and repairing engines. That meant that the worse the engines, the more repairs required and the more the money the company would make.?

However, things changed when the company realised there is no demand for a product that’s constantly in the repair shop. That prompted Rolls Royce to embrace servitisation.

Servitisation aligns the interests of the customer and those of the manufacturer to ensure everyone benefits. Rolls Royce has been offering this package to airlines since 2010, and the company has seen significant returns as a result.

Benefits

There are several benefits of incorporating servitisation into your manufacturing firm. Below are three of the strongest benefits

  • Financial Stability– Servitisation establishes a more secure revenue stream because of the long term connection between manufacturer and customer. This also translates to loyal customers, meaning more profit.
  • Strong Customer Retention Rate– Being more experienced about the equipment and the constant tracking and monitoring that comes with servitisation; manufacturers are realising that they can keep more customers.
  • Selling a Solution And a Product– Today customers are not just looking to buy a product, instead, they want both the product and the solution to their problem. Meaning you make more money for the product you manufacture and the service you offer to your customers.

Implementation of Servitisation in the Industry

To effectively implement servitisation, there must be an effective two-way flow of information and data in the supply chain. Meaning you may require software like FieldElite for scalable condition monitoring of performance. With FieldElite, for example, servitisation is made easier for you because it enables you to monitor the performance of your assets remotely.

Maintenance and monitoring of assets were traditionally very expensive and time-consuming until the arrival of intelligent software that makes work easier and cost-effective for manufacturers. FieldElite uses advanced learning algorithms to remotely automate the entire process, allowing you to detect, in real-time, the performance and need for maintenance on your asset.

Required Organisational Changes

A few important steps include;

Companies that invest in continuous training and development always have a more competitive edge than their counterparts. Meaning an important step towards servitisation is training the workforce. This is important, considering that the company structure, focus, and process will have to change.

Set up a team that is focused on the challenge, change, and creation. With this, you can easily adjust to industry changes. The team should always work on knowing what should be adjusted and when it should be.?

In the shift to servitisation, adopting a comprehensive service technology is an important step. Such service technology software includes FieldElite. This technology will ensure that you’re able to monitor your product in real-time, meaning you can maintain good performance for as long as possible.

Because servitisation essentially focuses on the customer, take time to study customer behaviour. Knowing what your customers need and want will help you remain relevant in the industry.

Conclusion

As the demand for more benefits and long-lasting relationships with dealers grow, so is the need for manufacturers to adjust. Hence more and more manufacturing companies are leaning towards embracing servitisation as a solution to the growing demand.?

In turn, manufacturers who’re attaching service contracts to their product sales are making more than those who remain stuck in the traditional approach to sales.?

Essentially, servitisation will ensure that, as a manufacturer, you remain relevant to your customers now and in years to come. This is a much better arrangement in terms of saving costs and making more returns. Remember to be successful, you have to be flexible enough to change with demand.

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