EXHIBIT 155 Business Processes and Technologies Affected in VS .NET

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EXHIBIT 155 Business Processes and Technologies Affected
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Sections Sec 302 Business Process Financial Reporting Technology Impacted ERP, SCM, CRM, MIS, Reporting Software, Enterprise Integration, ETL, Data Warehousing, Business Intelligence ERP, SCM, CRM, Enterprise Security, Secure Enterprise Integration, Business Process Mgmt, Workflow ERP, CRM, SCM, EAI, Business Activity Monitoring, Executive Dashboards, Business Performance Monitoring, Operational Intelligence Document Imaging and Records Management System, Knowledge Management Secure Communication System, Workflow and Document Management
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Sec 404
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Internal Controls
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Sec 409
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Reporting Material Events
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Sec 103
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Document and Records Management
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Sec 301
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Whistleblower Provision
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SARBANES-OXLEY FOR THE IT PROFESSIONAL
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ENDNOTES
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1 The CCO will usually be a person, with a legal and financial background, who has an understanding of enterprise functioning at the broad or big-picture level and also at the detail level She or he should have the appropriate authority within the company, and the CEO, CFO, and CIO should be accessible to her or him The key personnel in the enterprise should also believe in her or his capability and expertise The CCO can be either a consultant or a homegrown officer with a long history in the organization 2 Preferably external Sarbanes-Oxley specialist consultants, so that objectivity and authority are maintained 3 Location refers to the geographic location of a business unit 4 Sublocation refers to specific departments or workgroups within each location or business unit 5 Note that the SLC and SSLC of the implementation team are different from the SLC and SSLC of the audit team, to avoid role conflict
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APPENDIX
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Sarbanes-Oxley Implementation Plan: Developing an Internal Control System for Compliance (Focusing on Sections 302 and 404)
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n effective internal control system is integral to the ability to comply with Sarbanes-Oxley An internal control system is what will reduce the likelihood of noncompliance and alert the company to breaches, failures, or weaknesses in the system that must be addressed Internal controls as preventive and detective measures are the front line for ensuring that the regulatory requirements are being met, and thus much thought and consideration must be put into developing and maintaining those controls The following is a guide for achieving just that
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EIGHT-STEP PROCESS TO SOX COMPLIANCE
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An internal control system that meets the requirements of SarbanesOxley can be developed by following an eight-step process When a compliance plan is structured in this way, the journey to compliance is easy, and the system is easily implemented and followed The eight steps are: 1 2 3 4 Establish a compliance committee Assess risk Set reporting objectives Prepare a formal implementation plan 169
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170 5 6 7 8
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SARBANES-OXLEY IMPLEMENTATION PLAN
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Communicate the ongoing procedures Provide training Document processes and risk management Perform continuous evaluation
PROJECT MANAGER S STEPS TO SUCCESSFUL COMPLETION
Each of the eight steps in the compliance plan involves distinct processes The following is a list of the critical elements in each step 1 Establish a compliance committee Who
COMPLIANCE COMMITTEE Mandatory Members: Position CEO CFO Major Business Unit Heads: Name
Additional Recommended Members: Functional Areas Executives: Finance IT Legal Internal Audit
Sarbanes-Oxley Implementation Plan
Member characteristics include: Committed to Sarbanes-Oxley compliance Capable of taking a company-wide perspective regarding: Risk identification Suggested solutions What The compliance committee focuses on: Communicating program objectives and initiatives Managing the overall process and activities Providing training, assessment resources, and tools as necessary Engaging the various departments or business units to identify risks and solutions Keeping the goals of the committee visible and compelling 2 Assess risk Identify the corporation s appetite for risk as defined by the board Identify the types and scope of risks that the organization is facing as defined Review the board s risk guidelines Review the communication process for the risk guidelines Identify the enterprise-wide risks within the organization The number and types of risks will vary by type of business and other factors The general categories that should be reviewed for risks include: Financial risks for example, the risk of financial loss from investing in new acquisition or currency losses from exchange-rate fluctuations affecting international operations Human capital risk for example, the risk of not having qualified staff because of past deemphasis on college recruiting, or the risk of losing key staff members because of a below-market compensation program Legal and regulatory risks for example, operating in a highly regulated industry, such as nuclear power, or merely operating on the edge Strategic risks for example, growth through aggressive acquisitions, or operating too conservatively and letting competitors pass the organization by