An Enterprise Approach to Sarbanes-Oxley Compliance

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1 White Paper An Enterprise Approach to Sarbanes-Oxley Compliance The Business Objects Approach to Compliance Management

2 Author: Guy Weismantel Contributors: Cortney Claiborne, Davythe Dicochea, Jennifer Meegan Audience: Financial and IT managers responsible for compliance management initiatives within their organization Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance

3 Contents Introduction iv Paying Heed to Your Systems How to React to Sarbanes-Oxley with the Resources You Have Today How Technology Plays a Role in Addressing Sarbanes-Oxley Requirement How Business Objects Can Help Your Organization Address Sarbanes-Oxley Conclusion Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance iii

4 Introduction As the tide of corporate scandals and accounting irregularities begins to ebb, executives and financial managers alike are now faced with the task of adjusting to a new set of rules and demands from stockholders and the market at-large. The law that resulted from the public outcry to the fraudulent activities of some of the country s largest corporations is named after the two people who sponsored this landmark legislation: Senator Paul Sarbanes from Maryland and Representative Michael Oxley from Ohio. Its had a dramatic effect on both public and privately held companies. Industry analysts are comparing its impact to past Y2K projects. Everyone seems to have a solution consultants, software vendors, and publishers. Companies are rushing to market Sarbanes-Oxley products in an attempt to capitalize on the near-panic that some companies are experiencing. And they all have their own spin on how to solve this problem the magic elixir that will take care of everything. Against this backdrop, companies are being forced to take an even closer look at their internal operations. They are examining internal controls to determine if they have the ability to detect and take action on financial anomalies before the fiscal period ends. They are creating huge databases to store communication records as proof of their diligence, attention to detail, and their reactions to key business issues. And they are looking to their IT infrastructure to help them gain insight into their business not only to comply with shortened reporting requirements, but for assurance that the data they are analyzing and reporting is, to borrow a phrase, the truth, the whole truth, and nothing but the truth. But as is generally the case with such a far-reaching issue as the Sarbanes-Oxley Act (SOX), the approach that provides the quick fix or rapid return on investment (ROI) is often too good to be true. Leading companies recognize this and are taking a more strategic approach to ensuring their numbers measure up to the increased scrutiny of today s investor. They are using this law not as something that just needs a quick fix, but as an opportunity to take a look at processes and restructure the way they run their business. What s more, they are finding that they already have a lot of what they need in their company the right people, the right processes, and the right technology. In this paper, we ll explore the ways in which business intelligence (BI) and Business Objects can play a key role in this strategy. iv Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance

5 Pay Heed to Your Systems The Sarbanes-Oxley Act of 2002 has 15 distinct sections, ranging from the independence of company auditors and board of directors to filing deadlines and reporting requirements. Perhaps most significantly, the law names the executives who are responsible for both attesting to and certifying the financial results of the company on a regular basis. The implications are clear people are being held accountable, and there are consequences to illegal activity and sloppy bookkeeping. In the wake of this law, companies are looking to their systems infrastructure to help them ensure that they adhere to these new requirements. In a recent study commissioned by the research firm IDC, they stated, The Sarbanes-Oxley Act and the regulations that implement its provisions will have a major impact on the CFOs in their responsibility to deliver financial information on a timely basis. This will spur new requirements that will, in turn, impact the applications software used for financial analysis and business performance management 1 The implication is clear. The IT systems in place had better work. A better general ledger package alone won t cut it. SOX is not something that only affects the finance department it affects the entire organization from how the sales team recognizes revenue to how the shipping department records inventory acceptance and product delivery. It involves processes and internal controls throughout the organization, and makes all employees accountable for the results of the company. The systems used to support the processes are key, and they should support the processes in place or the new processes that must be created to adhere to the law. Often companies are unsure about where to start from a systems perspective. Many will throw technology at the problem and change their business processes to handle system changes. But this is the opposite of how best to proceed. Leading companies today should be reviewing and fixing internal processes first, and then mapping their systems to support these processes. It s a simple concept, but one that demands time and attention, both of which are in short supply in many companies today. Unfortunately, it s not something that can be addressed with workarounds. Rather, it s a fundamental area that must be dealt with completely and effectively before you can move any further. Leading companies are those that have strong internal processes in place to deal with the many requirements of this law. They are going back and looking at the time it previously took them to close their books and report results, and modifying the processes in place to meet the SOX requirements. They are identifying the individuals who report results, analyze metrics, and consolidate numbers, and determining if there is a better, more efficient way to expedite this work or gain increased visibility. Once these processes are in place, these companies are turning to their systems to see how they can help ensure compliance. If the processes can t be supported, it s time to change systems. In many cases, however, companies are finding that they already have as much as 75% of the technology they need in-house. Now that people are being asked to fix the problem without breaking the bank, all of those investments in analysis, reporting, and data integration certainly pay off. In the end, it all comes down to the systems in place and how to most effectively use their capabilities. 1. Sarbanes-Oxley: A Catalyst for a New Category of Analytic Applications, IDC, April Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance 1

6 The industry analyst firm IDC, in its April 2003 research note on Sarbanes-Oxley, published a comprehensive architecture framework for companies to comply with SOX regulations. The architecture, inserted below, helps serve as a guide to illustrate what leading companies already know you can integrate the systems you have today to help you deal with Sarbanes-Oxley requirements. Investors SEC Press/ Analysts STRATEGIC ANALYTIC APPLICATIONS FULL DISCLOSURE STRATEGIC ANALYTIC APPLICATIONS Full disclosure PROCESS-SPECIFIC ANALYTIC APPLICATIONS Compliance assessment FOUNDATIONAL Financial analytic applications & data model Compliance Consolidations Collect transaction level detail level based upon compliance framework Enhance transactions by collecting additional data required for compliance Auditability: Connection/recognition to source systems Investor & Regulatory Management Publish Reports Communicate with stakeholders Compliance Dashboard Compliance Report Card Finalize exceptions Certification checklists linking financial and operational data Sign-off and certification Compliance Analyzer Audit Workpaper Generation Exception alerts/audit trail of resolution Financial report preparation adjustments and audit trail What-if analysis Planning/BPM Applications Support planning versus actual analysis to identify exceptions Operational metrics that represent compliance Integrated benchmarking Collaborative Notes and Document Management Centralized Analytical Data Repository Extended enterprise data model incorporating a compliance data model Transactional G/L Data Compliance Data Model Rules & Algorithms SEC, FASB, IASB Other Transactional Data External Data Source: IDC, 2003 IDC s comprehensive IT architecture for dealing with Sarbanes-Oxley requirements. 2 Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance

7 How to React to Sarbanes-Oxley with the Resources You Have Today Companies have invested millions of dollars over the past several years to increase their financial reporting and analysis capabilities. In today s marketplace, leading companies can t afford to have multiple silos of information residing in dozens of different places. Rather, today s leaders subscribe to the one-version-of-the-truth mantra, meaning their business intelligence is leveraged across the entire enterprise so that, at the touch of a button, information on customers, products, revenue, costs, and profit is instantly available to them. So while the requirements of Sarbanes-Oxley may be new and more stringent than before, companies that have taken a strategic approach to enterprise reporting and analysis are finding that SOX is hardly cause for alarm. Even companies who view the reporting requirements as daunting often realize that by modifying key processes and using the available systems already in place, the law does not need to disrupt their business. For example, a company may determine that it needs increased visibility into cash outflows and the ability to investigate repeated payments to a vendor or payments above a certain threshold. Once the internal processes are in place regarding who is responsible for investigating this issue, and the frequency with which it is investigated, the company would turn to its accounts payable system and determine what system requirements there are to ensure that no unauthorized or fraudulent payments are being issued. This requirement doesn t necessitate the purchase of a whole new general ledger system. Instead, by using the current capabilities of the existing accounts payable system, new reports or business rules can be written to provide notification when certain thresholds or anomalies occur. Additionally, the financial transparency issue permeates each section of SOX. Gaining visibility not just into one department, but into many departments even the board of directors is a basic tenet of the law. In that regard, a company may already have a dashboard or extranet portal that is being used by a wide number of employees. It can be reconfigured to show key financial metrics or activity, providing for additional analysis, alerts, and recommended courses of action when something goes wrong. Again, the system is already in place. It just needs to be used more strategically. All of which is not to say that systems can solve all your problems in adhering to the law. But the good news is that today s leading companies are not starting from scratch as they scramble to implement new processes throughout the organization. Instead, they use their existing systems and technology to meet the requirements of the law. Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance 3

8 How Technology Plays a Role in Addressing Sarbanes-Oxley Requirements There are many different factors involved in meeting the requirements of a wide-ranging law like the Sarbanes-Oxley Act. In part, the law requires organizations to be able to: Consolidate information on a consistent basis in a timely manner Gain real-time visibility and be able to monitor automatically Provide rapid disclosure to shareholders of material events Provide real-time monitoring and alerting of variances Provide transparency throughout an organization Certify financial results under tight deadlines With all of these issues, technology and systems play a key role in helping organizations remain in compliance. Let s take a closer look at how this happens: Consistently Consolidate Information in a Timely Manner Technology is key when it comes to giving managers one view of the information across the entire company. Companies generally have between 10 and 40 different data sources from which they pull information most of which have important financial implications. These data sources can range from order entry and general ledger to sales order databases and promotional clearinghouses. The ability to see across them and be able to report accurately and rapidly is fundamental to ensuring data integrity for the end users of the information. Gain Real-Time Visibility and Automatic Monitoring This issue relies heavily on capabilities inherent in today s leading systems and applications. With SOX, it does no good to find out something happened after it s too late to do anything about it. On the contrary, the law puts the onus on the company to make sure it finds out what s wrong and takes action. Technological capabilities that give businesses this automatic insight, based on the unique processes within the company, are a necessity. Global operations in far-flung locations do not lend themselves to in-depth monitoring if the systems are not set up accordingly. Provide Rapid Disclosure to Shareholders of Material Events The key word is rapid. The law doesn t prohibit events from taking place and, in the normal course of business, it s obvious that there will be times when conditions change (such as 9/11). In the past, shareholders weren t always notified of these events until the damage had been done to the company. Technology plays a key role here by ensuring that the right documents get to the right people in time for them to take action. Whether it s through automatically published reports, scheduled or ad hoc analysis distributed to key stakeholders, systems play a central role. Provide Real-Time Monitoring and Alerting of Variances One of the problems with printing and distributing reports is that the information happened in the past. This is often useful, but doesn t directly address the issue of how to deal with what s happening now, or what may happen in the future. However, real-time technology is rapidly 4 Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance

9 maturing, and the ability to proactively alert users to anomalies, unfavorable trends, or material variances is central to adhering to SOX requirements. The key shift is from passive reporting to active performance management capabilities. For instance, monitoring trends goes right to the heart of reporting material events on a timely basis. Alerts allow people to take action and drill into the root cause of why something is happening so they can do something about it. And variance analysis enables companies to understand where business issues may lie. Was the plan wrong? Are the business conditions changing rapidly? What is causing this delta? These are all key questions that, on the surface, may seem harmless, but will ultimately have a material impact on your business. Provide Transparency throughout the Organization In retrospect, the lack of financial transparency clearly played a critical role in the downfall of many companies. Whether it was Enron s off-balance sheet partnerships or the executive embezzlement at Adelphia, these companies did not have the necessary visibility into their organizations to prevent these illegal activities from occurring in the first place. Perhaps the most glaring example of this was a statement in July 2002 from then WorldCom CEO John Sidgmore, who, when asked why the accounting irregularities in his company were not detected earlier in his far-flung operation stated, No single operating unit knows what s going on in the rest of the organization, and it all came together at CFO Scott Sullivan s level. Sullivan was fired shortly thereafter, and WorldCom declared bankruptcy three weeks later. Today, the business environment is radically different, and transparency is the rule rather than the exception. Technology is making it possible. Performance management initiatives notify users throughout the organization of changes in a single department. Teams no longer operate in silos. A single group can no longer operate without the scrutiny of the rest of the organization. Instead, by having one set of reporting and analysis tools across all data sources, executives and managers company-appointed overseers gain visibility into the company s operations any time, and at any place. Certify Financial Results under Tight Deadlines This issue is inherently dependent on the systems in place within an organization. The ability to automatically compile financial results, collaborate for variance analysis among groups, and consistently report across a common data model is paramount to credibly certifying the financial results of the company. There is no room to work on offline spreadsheets and one-off analysis. Technology is the key to ensuring this requirement is met. Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance 5

10 How Business Objects Can Help Your Organization Address Sarbanes-Oxley The Business Objects approach to helping companies address Sarbanes-Oxley requirements is a comprehensive strategy based on the breadth and depth of the Business Objects business intelligence platform. For our customers, one of the inherent advantages in approaching this issue is the nature with which we handle this challenge. BusinessObjects XI provides a comprehensive solution to help your company adhere to SOX reporting and analysis requirements. More importantly, the capabilities inherent within our product suite directly address the key business pains companies are facing today as a result of the law. Much of the foundation for a strategic approach to SOX lies in integrating the many disparate data sources within an organization. BusinessObjects Data Integrator has built connectors for integration with your company s key data sources. This is key to having one version of the truth from which to report financial and business results throughout the organization and to your company s stakeholders. There are many ways Business Objects can help companies deal with the numerous business pains they experience as a consequence of Sarbanes-Oxley. Consistently Consolidate Information in a Timely Manner BusinessObjects Data Integrator gives you one-system reporting off of multiple data sources. And with the BusinessObjects Warehouse, the enterprise data model will help you drive analysis throughout the organization, through prebuilt or customized analytics. Gain Real-Time Visibility and Automatic Monitoring Business Objects enterprise reporting, query and analysis tools, Dashboard Manager, and Performance Manager help you gain real-time alerting capabilities to executives and individuals throughout your organization. Dashboards and scorecards tied to metrics and goals within the 6 Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance

11 organization are essential for SOX-compliance and an integral component of the Business Objects product suite. Further, our new Sarbanes-Oxley Analytic Solution allows for root-cause analysis and analytic insight into the key financial areas, ensuring that you have access to every aspect of your far-flung operations. Provide Rapid Disclosure to Shareholders of Material Events Business Objects query, reporting and analysis tools, and Dashboard Manager and Performance Manager products, provide real-time alerting capabilities to executives and individuals throughout the organization. Provide Real-Time Monitoring and Alerting of Variances Financial metrics used in a public setting, such as earnings calls or analyst meetings, are subject to the same rules as written financial statements. Business Objects products provide key performance indicator (KPI) reporting, dashboards, and scorecards tied to metrics and goals within the organization and are essential for compliance with SOX and an integral component of the Business Objects product suite. Provide Transparency throughout the Organization Sarbanes-Oxley requires that you know what s going on in your business. BusinessObjects Performance Manager products provide workflow and collaboration capabilities, giving users throughout the organization the ability to work together to proactively address material events, trends, and unforeseen circumstances. Our suite of analytic applications provide the ability to drill to the lowest level of detail not just to the cost center or brand, but to the specific invoice, check, and purchase order. They also offer variance analysis on financial and operational activities, ranging from sales results, inventory analysis, and human resource reporting. Additionally, leading companies deploy extranets to give their key customers, suppliers, auditors, and directors role-based access to the key information needed to monitor the business. Certify Financial Results under Tight Deadlines BusinessObjects Broadcast Agent Publisher provides automated publishing and routing of reports and analysis to all areas inside (and outside to the board of directors and external auditors) the organization. Business Objects has the capabilities to help executives adhere to the many requirements of the Sarbanes-Oxley Act. However, there is one important aspect that must not be overlooked you must marry the technology with the expertise in order to implement the solution and help your company achieve its goals. In that regard, our Professional Services Organization, staffed by our certified consultants, can help you rapidly implement a system to meet a key SOX process and recommend process changes and adjustments that precede the system implementation. Our Education Services group delivers the training your users need to effectively use these systems. This training can be tailored to the time, place, and pace that best suits your organization s specific needs. Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance 7

12 Conclusion Papers on Sarbanes-Oxley are now a dime a dozen. Everyone has their own spin on how to comply with the law, why one section should be attacked first instead of another, and why their solution helps you get started out of the box. But leading companies today are taking a more strategic approach to solving this issue, and reassuring their investors that they can have confidence in the financial numbers being reported. By taking a strategic approach, these companies are realizing that they can accomplish the compliance requirements of the Sarbanes-Oxley Act in two steps: 1. By re-engineering their processes 2. By matching systems to those processes In this way, companies have found that using the enterprise systems they have in place today which provide them with a single version of the truth to report their numbers is the best way to approach the challenges imposed on the organization by SOX. These companies have realized that the vendors who provide a complete suite of applications and tools offer the best solution to implement SOX compliance requirements. Whether it s increased reporting and analysis, data integration across multiple and disparate sources, or real-time alerts on dashboards with trends and analytical insight, they need a comprehensive solution that helps them solve their system challenges. These companies are turning to Business Objects and our complete suite of products and services. By using our industry-leading capabilities, your organization will be able to address the challenges of Sarbanes-Oxley head on, while improving your company s performance. In today s marketplace, that s a great place from which to run your business. 8 Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance

13 Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance 9

14 10 Business Objects An Enterprise Approach to Sarbanes-Oxley Compliance

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16 Americas Business Objects Americas 3030 Orchard Parkway San Jose, California USA Tel: Asia-Pacific Business Objects Asia Pacific Pte Ltd 2 Shenton Way #18-02/06 SGX Centre 1 Singapore Tel: Europe, Middle East, Africa Business Objects SA rue Anatole France Levallois-Perret Cedex France Tel: Japan Business Objects Japan K.K. Head Office Yebisu Garden Place Tower 28F Ebisu, Shibuya-ku Tokyo Tel: For a complete listing of our sales offices, please visit our website. Business Objects owns the following U.S. patents, which may may cover cover products that that are are offered offered and and sold licensed by Business by Business Objects: Objects: 5,555,403; 5,555,403; 6,247,008 6,247,008 B1; 6,578,027 B1; 6,578,027 B2; 490,593; B2; 6,490,593; and 6,289,352. and 6,289,352. Business Objects, Business the Business Objects Objects and the logo, Business Crystal Objects Reports, logo, and Crystal BusinessObjects, Enterprise are Crystal trademarks Reports, registered Crystal Enterprise, trademarks Crystal of Business Analysis, Objects WebIntelligence, SA or its affiliated RapidMarts, companies and in the BusinessQuery United States and are trademarks other countries. or registered All other trademarks names mentioned of Business herein Objects may SA be or trademarks its affiliated of companies their respective in the United owners. States Product and specifications other countries. and All program other names conditions mentioned are subject herein may to change be trademarks without of notice. their respective Copyright owners Business Copyright Objects All rights Business reserved. Objects. All rights reserved. PT# WP2048-C WP2000-X Printed in the United States May 2005.

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