Sarbanes-Oxley is more than just a legal requirement. It can strengthen or
dilute business resources….beef-up important controls and disciplines or
suck the life out of a firm’s flexibility…..effectively utilize
operational data or just create another round of non-value added
reporting.
How you
approach the SOx requirements can make all the difference!
Among
other requirements, Sarbanes-Oxley requires a firm’s management to assess
the controls in place to ensure accurate financial reporting. Management
must assert that appropriate controls are in place and effectively
operating so that the resulting financial data fairly represent the firm’s
position. Management must also take into account information’that
does not appear on the income statement, balance sheet, or other financial
record, but that could materially affect that position. The impact of this
“off statement” information, along with the underlying controls, should
factor into the conclusions drawn by management.
Failing to
identify and utilize existing data can be very costly. Controls and
reporting may be duplicated, resulting in additional overhead without any
incremental benefit. Even if this information is not sufficient for SOx
compliance purposes, it is a start. In addition, existing significant
non-financial information may be invisible
to executive management and omitted when materiality is assessed. The ISOx
process is designed to help close these gaps.
Organizations
presently registered to ISO-based quality and environmental management
systems already collect and review data pertinent to SOx internal control
and/or materiality issues at a site level. Unfortunately, these data are
rarely visible to the functions and individuals with responsibility for
actually assessing the relevance of the data for SOx reporting purposes.
Often, controls
related to financial reporting link to underlying operational
controls.....controls over customer order review/entry, inventory
receipts/disbursements, purchasing, etc. These operational controls are an
important source of objective evidence for SOx 404 compliance.