Leveraging Sarbanes-Oxley (SOX) to Build Better Practices
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- Elfrieda Gardner
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1 Leveraging Sarbanes-Oxley (SOX) to Build Better Practices Powering Strategies and Managing Risks Using SOX compliance to build disciplined, repeatable, and auditable practices. Running a successful business just got a lot more complicated for many publicly traded and GAAP-compliant organizations. Fraud and mismanagement by executives of highly visible public companies such as Enron, Tyco, WorldCom, Global Crossing and others have created an atmosphere of executive mistrust. At the same time, many Internet Companies had spectacular failures that drove the technology stock market into a tail spin. As a response, the Sarbanes-Oxley (SOX) Reform Act, passed into federal law in 2002, has created new federal requirements for the way publicly-held companies report their finances. It has also made non-compliance into a personal risk for the CXOs and the executives of the organization, who face fines and jail time. (See page 2) PlanView Portfolio Management which includes governance processes, workflow, financial tracking, and auditable decision trails is becoming a key tool to manage risks and regulatory compliance for SOX and other requirements. The only way for executives to mitigate Some SOX Imperatives An audit trail of decisions Faster financial reporting Attesting to internal control structures Improved project success rate A portal to track the SOX compliance project itself What PlanView Portfolio Management Offers PlanView uses a stage/gate technique to track and manage new opportunities from the investment analysis stage, to the project/program stage, and on to the stage where the deliverables are deployed as assets. At each decision gate, PlanView records an audit trail showing: date, decision, ID of decision-maker, notes, as well as the previous and the following decisions. PlanView speeds and supports investment and portfolio decisions with PlanView PRISMS for IT Governance. PRISMS are real-time processes deployed within PlanView software. PlanView tracks labor and costs on projects and other work down to the task level, if required. Tracking at the phase level supports capitalization reports as required by GAAP SOP Create simple reports in PlanView or export to almost any ERP, financial software, HR, etc. PlanView s integrated time and expense tracking have been shown to reduce time for chargeback reports and billing by an average of 4.0 weeks (Aberdeen PSA User Survey, 2001) PlanView delivers software and processes for enterprise portfolio management, including control structures such as lifecycle roles, workflow automation, collaborative portals, content templates and more. Process architects at customer sites tailor new processes and templates as needed. Using PlanView s investment analysis helps organizations align new work with business strategies. Formal work initiation processes ensure that only the right work gets started. PlanView manages changes and issues with formal risk escalation and management; also auditable and also integrated with portfolio management. Less risk = more project success. PlanView not only supports SOX compliance, it s becoming a key solution for managing the SOX compliance project. All managers, team members, and associates access real-time status via a PlanView portal. PlanView helps you optimize the performance of your organization and maximize productivity from your resources. PlanView Web Software is the world leader in web-based, integrated portfolio, project and resource management tools and processes. Headquarters are in Austin, Texas USA (tel ), with offices across the USA, in the UK and Ireland (Tel ), Italy (Tel ), France (Tel ), Benelux (Tel ), and the rest of Europe (Tel ).
2 SOX in a Nutshell: Personal Liability, the Audit Trail & Fast, Fast, Fast The Sarbanes-Oxley (SOX) package of reforms signed into law 2002 through 2003 defines personal liabilities for the CEO and CFO and requires a digital audit trail of financial decisions. The act which affects all publicly traded companies with a market capitalization of over $75-million (under $75M get an extra year) includes the following: Quarterly reporting must be done in 35 days compared to the previous 45 days. Annual reporting must be done in 60 days compared to the previous 90 days. Significant events must be reported in plain English and within 2 days compared to the previous 5 to 15 days. The CEO and CFO are required to verify the effectiveness of the financial controls they use to keep auditors up to date. The impact of not complying: personal fines of up to $1 million and up to 10 years in prison, or both. If a CEO or CFO is found to be willfully misleading, the fine goes to $5 million and up to 20 years in prison or both. Other parts of the act address the liabilities of accounting firms. Achieving the agile or real-time enterprise has been a key business strategy for the past several years because it can lead to higher revenues and market share. Now it s seen as a way to fight risk. Executives have developed a keen focus on business risks because they are being held personally responsible by the government, stockholders and employees for the results of their business decisions. The only way for executive to mitigate their risks is to use IT to power business processes that operate in near real-time, that are repeatable and auditable. Sarbanes-Oxley is providing the impetus for a series of compliance issues related to IT. CEOs and CFOs are now required to attest that annual and quarterly financial reports contain no material errors or omissions. With their own necks suddenly on the line, these executives are scrambling to make sure their systems are more timely and accurate. Short of giving a blank cheque to IT, CEOs should be more willing to sign off costly overhauls of their existing financial reporting, budgeting, and supporting business intelligence systems. Computer Business Review, May 2003 their risks is to empower business processes that operate in near real-time, that are repeatable and auditable. IT is the engine that drives business processes, so the IT group has now been made even more critical to the well-being of the CXO. While at the same time, the CIO is getting more visibility at the board level and must justify and support his or her technology decisions in business terms. PlanView would like to offer some thoughts on how to go beyond mere SOX compliance. The idea behind the SOX reforms is to establish a broad, digital paper trail to prove the corporate financial reports are open and honest. Yet SOX is the tip of a much broader effort to use IT to improve business processes. In one 2003 study by the Meta Group, 65% of the respondents are seeking to use SOX to achieve process enhancements to improve efficiency and competitive advantage. Only 20% were focused merely on compliance. As PlanView customers are doing, implementing governance processes, work initiation processes, investment analysis, and just-in-time mentoring can help your organization elevate your business processes to a competitive advantage. The CIO Impact: Technology + Business Issues IT expenditures can no longer be justified on their technical merit alone; they have to be justified in clear business terms. IT expenditures are now as intensely scrutinized as any other expense, and a backlash is partly to blame. Many senior executives who authorized large IT capital expenditures in the boom years now have the impression that IT organizations are wasteful, willful and need to be controlled. This has driven the CIO to look for greater understanding of business strategies and strategic alignment. In some cases the CIO is evolving into the owner of the organization s strategic processes. Titles like CIO and VP of Strategy are growing common in companies where IT acts as the engine of corporate growth. The result? IT governance processes are becoming essential not only to the advancement of the CIO, but to the survival of the corporation. Sarbanes-Oxley Paper p. 2
3 PlanView uses a stage/gate structure for workflow and internal control of projects Distribute Decisions Through Governance IT Governance is defined as repeatable, disciplined and auditable methods of decision-making, communicating, performing and delivering real benefits to the organization. It integrates strategic decision-making with the work and resource management in a consistent, auditable workflow to give a comprehensive picture to everyone with a vested interest in the process. Some of the key components of IT Governance are: Apply a work initiation process to focus resources on the right work. Clarify investment decisions by analyzing risks and dependencies before funding and then clearly communicate the results. Measure portfolios of work and resources to make early decisions about their performance to eliminate non-productive work and realign resources. Plan to the capacity of the organizational resources to align the workforce with the pipeline of projects, service requests and on-going work. Execute all work to a high standard of quality and eliminate surprises by collaborating across the enterprise during execution and managing changes and risks. Assure the work really delivers the promised benefits to the organization and capture knowledge about best practices and resource performance. Converging Trends Improving corporate processes will reduce risk, and meet the real business needs of saving costs and improving productivity, while also supporting the internal control structures required by SOX regulations. Some organizations look at regulatory requirements and believe they can be satisfied just by giving executives more information. They are missing the point, or are at least far behind the power curve. Compliance comes from management decisions being made based on disciplined, repeatable and auditable processes. IT governance is how technology becomes the pedal that accelerates business strategies. Managing business strategies & risks and IT governance are on converging paths. IT is the only way to meet the speed, accuracy, repeatability and auditability that are required in business processes. IT is the engine of corporate processes. PlanView Portfolio Management Our solution provides a set of IT governance processes that nest within internal control processes of the whole organization. PlanView s IT Governance includes initializing, scoping, ranking, prioritizing, resource planning and monitoring of projects, service work, and standard activities through portfolios. Our portfolio management software uses a web-based application infrastructure which Continued on page 6 p.3
4 PlanView portfolio management includes time-phased cost & benefit forecasting & tracking, lifecycle workflow with role assignments, full-featured document management, investment analysis and more. Sarbanes-Oxley Paper p. 4
5 PlanView s Audit Trails Incorporate Organizational Roles Role Description Governance Board (GB) Project Management Office (PMO) Investment Owner (IO) Customer (Customer) Executive Sponsor (ES) Project Manager (PM) Resource Manager (RM) Project Team (PT) Financial Manager (FM) Business Analyst (BA) Executive management sets the governance process, which varies by the investment type, size of investment and other key factors. PlanView s default set-up includes three governance boards depending on the investment classification Local, Group and Strategic since strategies are different for each one. The Project Management Office (PMO) is responsible for setting and encouraging standards and acting as an agent for the governance board for lifecycle steps before the project manager is assigned. The investment owner decides which investments to fund and is responsible for tracking performance and adjusting the portfolio of investments based on changes in strategy, performance, market conditions, etc. The customer initializes the investment request and is responsible for defining basic request information. Customers can be internal LOBs or external. The executive sponsor reviews the goals of the project and is the authority for scope changes, risk planning and changes to the deliverables. The project manager is responsible for the planning and execution of the project. The resource manager is responsible for supplying skilled resources to meet work requirements. The project team includes all lifecycle roles associated with the project. The financial manager is responsible for confirming the funding for projects is within organizational guidelines and is properly identified in the organization s accounts. The business analyst is responsible for reviewing the project definition and completing the appropriate documents to guide the governance board on the project scope. p.5
6 has core functionality for work initiation, workflow, content management, collaboration, configurable portals and business intelligence to deliver a broad range of functionality including: project management, service management, resource management, time & expense tracking, strategic management, investment analysis, performance tracking and financial forecasting. PlanView s PRISMS for IT are governance processes that include workflows, best practices, collaboration, content documents, manager tools and more. You can implement the processes, modify them to your unique needs or automate your own methods with the PlanView process architecture tools. The processes are a part of software and services that automates the delivery of mature, proven solutions. Giga Group reports in 2003 estimated that a 20% process improvement can reap productivity improvements of up to 80%. PlanView offers tools and pre-built processes to improve your own business processes by making them consistent, repeatable, disciplined and auditable. You reduce executive liability to stockholder or regulatory reviews and improve organizational performance. Create Real Value With PlanView A large cross-section of the organization will typically be involved in SOX compliance. PlanView helps you speed your decision cycle with access to repeatable methods, real-time metrics and information at the level of detail each user wants and needs. The results: Costs are controlled Redundant work is identified and eliminated Dependencies are clarified and managed Risks are recognized and mitigated Staff is focused on the right work PlanView Portfolio Management Software integrates a set of governance processes into a single application infrastructure to provide strategic management, project & service management and resource management. Through the PlanView solution, individual Manage SOX compliance in its own project portal in PlanView. projects, service requests and on-going work are managed in context of the overall organizational strategies. Resource demands can be forecasted and capacities evaluated for staff, capital and other resources. Projects and service are linked into portfolios to evaluate their larger impact on strategies for programs, products, initiatives and more. Investment decisions are based on concise, repeatable models to focus resources on the right work. Resource overloads and under-utilization are addressed with real-time information to optimize resource usage. Your governance processes are encouraged and monitored by PlanView software. Time and expenses are managed and tracked down to the task level for reporting and chargeback. Documents, tools, notifications and information are delivered to the appropriate person at the appropriate time through workflow. Real-time performance information is shared across the organization. For more information, additional PlanView Position Papers, or to see a demo, please contact us at In the U.S. Tel: p.6 Copyright 2003 PlanView, Inc. All rights reserved. Level I document. Version 2003-September-18. PlanView is a registered trademark of PlanView, Inc. PRISMS, Scoreboard and HomeView are trademarks of PlanView Inc. All other trademarks are acknowledged. PlanView may vary the specifications and availability of these products and services without notice.
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