SARBANES-OXLEY IMPLEMENTATION PLAN in .NET

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EXHIBIT A3 Monitoring the Audit: SOCKET Audit Team
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Monitoring The Audit: SOCKET Audit Team The SOCKET audit team is monitored by the Sarbanes-Oxley compliance committee at the corporate level This is done on a periodic and ongoing basis Comprehensive Analysis: The CIO goes through the strategic- and tactical-level analysis documents An As-Is report is jointly prepared A gap analysis with respect to Sarbanes-Oxley compliance is prepared Risk control areas and internal control systems need to be identified From this analysis, two reports are prepared: An interim compliance plan that focuses on the immediate steps to be taken for controlling the risk and temporary arrangements for Sarbanes-Oxley compliance A To Be report on implementing a Sarbanes-Oxley compliant framework At this point, a detailed project plan is developed, detailing the processes, technology, people, and total cost of compliance required to address each gap, risk control area, and internal control system The COO or CCO makes a final presentation to the CFO and CEO Once approved, the SOCKET implementation team takes responsibility for implementing the project SOCKET Implementation Completed Implementation The SOCKET implementation team reengineers the key business processes with the help of external consultants Technology Existing technology: All the process charts, manuals, and other relevant documentation are assembled and understood The reengineered business process is mapped to various configurations of the existing technology until a suitable reconfigured technology ecosystem design with minimal gaps is reached The remaining gaps in the new ecosystem and the reengineered business processes are identified to be filled in by new technology New Technology: Define precise specifications required for the new technology Identify and evaluate potential products and vendors Transition to new technology with appropriate data migration and change management People: Training IT Users IT maintenance team
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Sarbanes-Oxley Implementation Plan
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Audit: Postimplementation Strategic Audit the To Be documentation against the implementation of the new ecosystem Tactical Use the noncompliance report form to document the findings Bring to notice any discrepancies between Sarbanes-Oxley requirements and the reengineered business processes Results supplement the strategic audit NCR closing procedures are continued on an ongoing basis throughout the lifetime of the organization Ongoing Monitoring Of Process And Technology Strategic Strategic audits are carried out on a periodic basis; for example, quarterly, semiannually, or annually Tactical Tactical audits are carried out on an ongoing basis to ensure compliance throughout the lifetime of the organization Continuous Alignment with Business and Governance Goals During the periodic strategic audits, review the alignment of the ecosystem with the strategic goals of the enterprise
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Antifraud programs and controls Controls, including IT general controls, on which other controls depend Controls over significant nonroutine and nonsystematic transactions, such as accounts involving judgments and estimates Controls over the period-end financial reporting process, including controls over procedures used to enter transaction totals into the general ledger; and to record recurring and nonrecurring adjustments to the financial statements (eg, consolidating adjustments, report combinations and reclassifications)
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Factors to be considered when determining whether a system should be reviewed and tested include:
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Does it process large volumes of transactions Does it process large-dollar-value items Is it used to process complex transactions Is it used to support highly sensitive financial data repositories
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SARBANES-OXLEY IMPLEMENTATION PLAN
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SOCKET IMPLEMENTATION TEAM CEO CFO COO SOX Champion CIO SOCKET Head SOCKET Audit Team Special training for IT users and staff SOX Compliance Committee
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Strategic-level analysis (top-down approach)
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Tactical-level analysis (bottom-up approach)
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Comprehensive analysis by combining top-down and bottom-up approaches
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Interim plan Mostly based on people support CCO and SOX Compliance Team CEO + CFO
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Detailed plan covering processes, technology, and people CCO and SOX Compliance Team
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SOCKET Implementation Team Periodic reaudit Implement BPR Reconfigure existing technology Ongoing tactical audit Buy new technology Train people
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SOCKET implementation completed
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EXHIBIT A4 SOCKET Implementation Team
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Which locations or business units should be included Consider:
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The extent of dependence on IT at the various locations or business units The degree of consistency in processes and procedures with other locations or business units Where processes and procedures are unique, organizations may need to consider these locations separately and ensure that overall control objectives are met The organization s assessment of risk related to the location or business unit
Perform Risk Assessment Risk assessment requires two perspectives: 1 Impact reflects the effects of events 2 Probability or likelihood reflects the potential for events to occur
Identify Significant Account/Controls Identify significant accounts that could have a material impact on the financial reporting and disclosure process Identify application controls relevant to the identified significant accounts
Document Control Design Documentation takes many forms, including paper, electronic files, and other media; and can include a variety of information, such as policy manuals, process models, flowcharts, job descriptions, documents, and forms The form and extent of documentation will vary depending on the size, nature, and complexity of the company Management should discuss the proposed extent and detail of the documentation with the external auditors early in the process Documentation should be prepared at both the entity level and the