Spreadsheet Woes – Burden in SOX Compliance and Other Regulations

End User Computing (EUC) or end User Developed Application (UDA) systems like spreadsheets used to be ideal ad-hoc solutions for data processing and financial reporting. But those days are long gone.

Today, due to regulations like the:

  • Sarbanes-Oxley (SOX) Act,
  • Dodd-Frank Act,
  • IFRS (International Financial Reporting Standards),
  • E.U. Data Protection Directive,
  • Basel II,
  • NAIC Model Audit Rules,
  • FAS 157,
  • yes, there?s more ? and counting

a company can be bogged down when it tries to comply with such regulations while maintaining spreadsheet-reliant financial and information systems.

In an age where regulatory compliance have become part of the norm, companies need to enforce more stringent control measures like version control, access control, testing, reconciliation, and many others, in order to pass audits and to ensure that their spreadsheets are giving them only accurate and reliable information.

Now, the problem is, these control measures aren’t exactly tailor-made for a spreadsheet environment. While yes, it is possible to set up a spreadsheet and EUC control environment that utilises best practices, this is a potentially expensive, laborious, and time-consuming exercise, and even then, the system will still not be as foolproof or efficient as the regulations call for.

Testing and reconciliation alone can cost a significant amount of time and money to be effective:

  1. It requires multiple testers who need to test spreadsheets down to the cell level.
  2. Testers will have to deal with terribly disorganized and complicated spreadsheet systems that typically involve single cells being fed information by other cells in other sheets, which in turn may be found in other workbooks, or in another folder.
  3. Each month, an organisation may have new spreadsheets with new links, new macros, new formulas, new locations, and hence new objects to test.
  4. Spreadsheets rarely come with any kind of supporting documentation and version control, further hampering the verification process.
  5. Because Windows won’t allow you to open two Excel files with the same name simultaneously and because a succession of monthly-revised spreadsheets separated by mere folders but still bearing the same name is common in spreadsheet systems, it would be difficult to compare one spreadsheet with any of its older versions.

But testing and reconciliation are just two of the many activities that make regulatory compliance terribly tedious for a spreadsheet-reliant organisation. Therefore, the sheer intricacy of spreadsheet systems make examining and maintaining them next to impossible.

On the other hand, you can’t afford not to take these regulations seriously. Non-compliance with regulatory mandates can have dire consequences, not the least of which is the loss of investor confidence. And when investors start to doubt the management’s capability, customers will start to walk away too. Now that is a loss your competitors will only be too happy to gain.

Learn more about our server application solutions and discover a better way to comply with regulations.

More Spreadsheet Blogs


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Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry


How Internal Auditors can win the War against Spreadsheet Fraud


Spreadsheet Reporting – No Room in your company in an age of Business Intelligence


Still looking for a Way to Consolidate Excel Spreadsheets?


Disadvantages of Spreadsheets


Spreadsheet woes – ill equipped for an Agile Business Environment


Spreadsheet Fraud


Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


Server Application Solutions – Don’t let Spreadsheets hold your Business back


Why Spreadsheets can send the pillars of Solvency II crashing down

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2015 ESOS Guidelines Chapter 2 – Deadlines and Status Changes

The ESOS process is deadline driven and meeting key dates is a non-negotiable. The penalties for not complying / providing false or misleading information are ?50,000 each. Simply not maintaining adequate records could cost you ?5,000. The carrot on the end of the stick is the financial benefits you stand to gain.

Qualifying for inclusion under the ESOS umbrella depends on the status of your company in terms of employee numbers, turnover and balance sheet on 31 December 2014. Regardless of whether you meet the 2014 threshold or not, you must reconsider your situation on 31 December 2018, 2022 and 2026.

Compliance Period Qualification Date Compliance Period Compliance Date
1 31 December 2014 From 17 July 2014* to 5 December 2015 5 December 2015
2 31 December 2018 From 6 December 2015 to 5 December 2019 5 December 2019
3 31 December 2022 From 6 December 2019 to 5 December 2023 5 December 2023
4 31 December 2026 From 6 December 2023 to 5 December 2027 5 December 2027

Notes:

1. The first compliance period begins on the date the regulations became effective

2. Energy audits from 6 December 2011 onward may go towards the first compliance report

Changes in Organisation Status

If your organisation status changes after a qualification date when you met compliance thresholds, you are still bound to complete your ESOS assessment for that compliance period. This is regardless of any change in size or structure. Your qualification status then remains in force until the next qualification date when you must reconsider it.

Saving Energy Step 2 ? More Practical Ideas

In my previous blog, we wrote about implementing a management system. This boils down to sharing a common vision up and down and across the organisation, measuring progress, and pinning accountability on individuals. This time, we would like to talk about simple things that organisations can do to shrink their carbon footprints. But first let’s talk about the things that hold us back.

When we take on new clients we sometimes find that they are baffled by what I call energy industry-speak. We blame this partly on government. We understand they need clear definitions in their regulations. It’s just a pity they don’t use ordinary English when they put their ideas across in public forums.

Consultants sometimes seem to take advantage of these terms, when they roll words like audit, assessment, diagnostic, examination, survey and review across their pages. Dare we suggest they are trying to confuse with jargon? We created ecoVaro to demystify the energy business. Our goal is to convert data into formats business people understand. As promised, here are five easy things your staff could do without even going off on training.

  1. Right-size equipment? outsource peak production in busy periods, rather than wasting energy on a system that is running at half capacity mostly.
  2. Re-Install equipment to OEM specifications ? individual pieces of equipment need accurate interfacing with larger systems, to ensure that every ounce of energy delivers on its promise.
  3. Maintain to specification ? make sure machine tools are within limits, and that equipment is well-lubricated, optimally adjusted and running smoothly.
  4. Adjust HVAC to demand ? Engineers design heating and ventilation systems to cope with maximum requirements, and not all are set up to adapt to quieter periods. Try turning off a few units and see what happens.
  5. Recover Heat ? Heat around machines is energy wasted. Find creative ways to recycle it. If you can’t, then insulate the equipment from the rest of the work space, and spend less money cooling the place down.

Well that wasn’t rocket science, was it? There are many more things that we can do to streamline energy use, and coax our profits up. This is as true in a factory as in the office and at home. The power we use is largely non-renewable. Small savings help, and banknotes pile up quickly.

Transformation to a process based organisation

Today’s global marketplace rewards nimble organisations that learn and reinvent themselves faster than their competition. Employees at all levels of these organisations see themselves as members of teams responsible for specific business processes, with performance measures tied to the success of the enterprise. As team members, they are “owners” of the process (or processes) to which they are assigned. They are responsible for both the day to day functioning of their process(s), and also for continuously seeking sustainable process improvements.

Transforming a traditionally designed “top down control” enterprise to a process-based organisation built around empowered teams actively engaged in business process re-engineering (BPR) has proven more difficult than many corporate leaders have expected. Poorly planned transformation efforts have resulted in both serious impacts to the bottom line, and even more serious damage to the organisation’s fabric of trust and confidence in leadership.

Tomislav Hernaus, in a publication titled “Generic Process Transformation Model: Transition to Process-based Organisation” has presented an overview of existing approaches to organisational transformation. From the sources reviewed, Heraus has synthesised a set of steps that collectively represent a framework for planning a successful organisational change effort. Key elements identified by Hernaus include:

Strategic Analysis:

The essential first step in any transformation effort must be development of a clear and practical vision of a future organisation that will be able to profitably compete under anticipated market conditions. That vision must be expected to flex and adjust as understanding of future market conditions change, but it must always be stated in terms that all organisational members can understand.

Identifying Core Business Processes:

With the strategic vision for the organisation in mind, the next step is to define the core business processes necessary for the future organisation to function. These processes may exist across the legacy organisation’s organisational structures.

Designing around Core Processes:

The next step is development of a schematic representation of the “end state” company, organised around the Core Business Processes defined in the previous step.

Transitional Organisational Forms/ Developing Support Systems:

In his transformation model, Hernaus recognises that information management systems designed for the legacy organisation may not be able to meet the needs of the process management teams in the new organisation. Interim management structures (that can function with currently available IT system outputs) may be required to allow IT professionals time to redesign the organisation’s information management system to be flexible enough to meet changing team needs.

Creating Awareness, Understanding, and Acceptance of the Process-based Organisation:

Starting immediately after the completion of the Strategic Analysis process described above, management must devote sufficient resources to assure that all organisation members, especially key managers, have a full understanding of how a process-based organisation functions. In addition, data based process management skills need to be provided to future process team members. It is not enough to schedule communication and training activities, and check them off the list as they are completed. It is critical that management set behavioural criteria for communication and training efforts that allow objective evaluation of the results of these efforts. Management must commit to continuing essential communication and training efforts until success criteria are achieved. During this effort, it may be determined that some members of the organisation are unlikely to ever accept the new roles they will be required to assume in a process-based organization. Replacement of these individuals should be seen as both an organisational necessity and a kindness to the employees affected.

Implementation of Process Teams:

After the completion of required training AND the completion of required IT system changes, process teams can be formally rolled out in a planned sequence. Providing new teams with part time support by qualified facilitators during the firsts weeks after start-up can pay valuable long term dividends.

Team Skill Development and Continuous Process Improvement:

Providing resources for on-going skill development and for providing timely and meaningful recognition of process team successes are two keys for success in a process-based organisation. Qualified individuals with responsibility for providing training and recognition must be clearly identified and provided with sufficient budgetary resources.

The Hernaus model for transformation to a process based organisation is both well thought out and clear. His paper provides an ample resource of references for further study.

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