1 Contact Information •Dan Aldridge CEO Performa Apps •e-mail dan.aldridge@i-app.com •website www.inforln.com/wp •linkedin Dan Aldridge •twitter @Danaldridge1 • Agenda Introduction DynaFlow Governance Risk & Compliance / Enterprise Risk Management Segregation of Duties for Baan / LN Impact on ERP implementation Contact details: Aart de Glint adeglint@dynaflow-solutions.com Phone +31 318 479712 Mobile +31 654 392046 3 DynaFlow Profile Main Facts: Established in 1997 Private company HQ in Canada Partners in USA, France, Netherlands, Norway, India, Thailand and Australia Main mission: To enable global companies to become “Simply in Control” by proactively managing enterprise risks, demonstrating compliance and automating and optimizing business processes. Dedicated to provide its clients a fast ROI through a short and structured implementation Professional Services: Implementation and Training Compliance & Audit Support Process Optimization Solution Hosting Services 4 DynaFlow: Makes it EZ for... 6 Cooking the Books Mr. Ebbers (WorldCom), Mr. Lay (Enron), Mr. Kozlowski (Tyco) http://www.cbsnews.com/video/watch/?id=859384n 7 8 Regulation - The Hot Potato Loi sur La Sécurité Financière (LSF) SAS-70 C-SOX SOX IFRS ‘Euro-SOX’ Code Lippens 21 CFR Part 11 9 Basel-II BilMoG Code Tabaksblat 8th EU Directive Clinger Cohen J-SOX Governance, Risk Mngnt & Compliance Governance describes the overall management approach through which senior executives direct and control the entire organization, using a combination of management information and hierarchical management control structures. Governance activities ensure that critical management information reaching the executive team is sufficiently complete, accurate and timely to enable appropriate management decision making, and provide the control mechanisms to ensure that strategies, directions and instructions from management are carried out systematically and effectively. Risk management is the set of processes through which management identifies, analyzes, and, where necessary, responds appropriately to risks that might adversely affect realization of the organization's business objectives. The response to risks typically depends on their perceived gravity, and involves controlling, avoiding, accepting or transferring them to a third party. Whereas organizations routinely manage a wide range of risks (e.g. technological risks, commercial/financial risks, information security risks etc.), external legal and regulatory compliance risks are arguably the key issue in GRC. Compliance means conforming with stated requirements. At an organizational level, it is achieved through management processes which identify the applicable requirements (defined for example in laws, regulations, contracts, strategies and policies), assess the state of compliance, assess the risks and potential costs of non-compliance against the projected expenses to achieve compliance, and hence prioritize, fund and initiate any corrective actions deemed necessary. 10 GRC/ERM Support at all levels Levels of GRC model •Policy •Enterprise Risk Management (Strategic) •Integrated Compliance Frameworks •Consolidated Dashboards (Control Statements) Strategical •Review Tactical •Test Operational Purchasing Warehouse Management Manufacturing •Procedures •Process Risk Analysis (Tactical) •Process & Internal Control Design & Maintenance •Review (workflow) •Monitoring Efficiency of Internal Controls •Embedded testing & test evidence •Document Management System •KPI/”In Control” reports Sales & Distribution Continuous monitoring as part of normal business process •Policy •Enterprise Risk Management (Strategic) •Integrated Compliance Frameworks •Consolidated Dashboards (Control Statements) Compliance – Why is this important Regulation Corporate & Executive Responsibility & Liability Fear for Reputation Damage Tightened Credit Lines Premium Insurance Fees Policy Interpretation Implementation Cost Overhead Audit Cost From Regulation to Compliance Regulations Implementation Framework Policy & Procedure Implementation Evidence Collection Business Risks SOX ERM Business Controls: - Information delivery - Resource acces and use - Risk mitigation - ... HIPAA COSO-II BASEL II COBIT ... Demonstratiopn of Compliance Demonstratiopn of Compliance Demonstration of Compliance Etc. establish People Processes document Technology Audit test Facilities Data SOX Section 404 – Internal Control Assessment of internal control “The most contentious aspect of SOX is Section 404, which requires management and the external auditor to report on the adequacy of the company's internal control over financial reporting (ICFR). This is the most costly aspect of the legislation for companies to implement, as documenting and testing important financial manual and automated controls requires enormous effort.” http://www.heritage.org/CDA/upload/SOX-CDA-edited-3.pdf 14 SOX Internal Control Requirements Documentation Detailed Process description Process flowchart (preferable) Business Risk Assessments Risk Control Matrix (RCM) Testing Annual walkthrough of each process. Testing of key controls. Periodic Reviews Review of process steps and controls Updating of all documentation Annual External IC Audit Essentially external validations that yes you did 1 through 3 above. The auditor would use a predefined “checklists 15 RISK / CONTROL MATRIX R007 R011 R042 R075 16 What ensures that purchases are recorded into the proper accounting period? What ensures that invoice prices, quantities and other valuation information is correct? What ensures that duplicate and/or fictitious purchases are not recorded? What ensures that perpetual inventory records reflect proper quantities and amounts? Risk R079 What ensures that perpetual-to-physical inventory adjustments are correctly calculated and recorded? R093 What ensures that inventory counts, compilations and descriptions are accurate? Auditor Assertion ACP-C01 Completeness PC Completeness, E/O, M/V Existence/ Occurrence Existence/ Occurrence Completeness, Measurement/ Valuation Measurement/ Valuation ACP-C04 ACP-C16 PC PC PC PC Cycle coun ts t quan tity o ha t re sult utsid in a d r evie e lim iffer w ed its se t by c ence from ar e r e ; it ems w o p ith a c oun var an m pa ny po e rpet ua l te d. li ce de em ed cy ar e to be m ate rial A ll pu r ch includ ase or der s and ing le non-P dge ac cor O inv da nce r ac coun oice s tc w ith ar e re com p oding, a n vie d a re a ny p a ut ho we d, olicy. rize d in Fo r p r od into t uc tion inv oic es he , inv r ece ip system fo r auto oice s ca n t ar e m atic only alr ea the in be e n dy in mat c voic t inform e pric e a the sys tem hing if a v er ed nd du alid P ation O and e dat . The syst . e e info r ma t m popula t ion fr A ll un om t h e s ma e PO for fo tc he d PO invoic llowup. es a re for wa r ded to pu rc ha s ing A ll no n-P into t O invoice s re ce he sy stem iv prope within e d at m o r inclu nt h e 3 da y sion in nd a r s of e ent to Ac e coun m ont h-e n ts Pay d t o e re d able. nsure Risk / Control Matrix PUR-C11 INV-C18 PC DC DC DC PC = Preventive Control DC = Detective Control Enterprise Risk Management (ERM/GRC) The key pains & challenges: Extra burden “on top” of running the company Draining resources from critical projects Absence of clear and documented guidelines Absence of automation Cannot be postponed (scheduled audits) Cost (with NO tangible ROI) The proposed approach & resolution: Leverage pre-defined knowledge via libraries Avoid multiple partial systems (and integration burden) Automate as much as possible tedious and large volume tasks How DynaFlow supports ERM/GRC Business Risks & Business Controls Library 2,500+ pre-defined Controls, Risks and relationships Certified Best Practices / Benchmark For all regional & industry specific regulations (SOX, Basel-II, L262, FDA, HIPAA, IFSR, ISO, etc…) To address all auditing/auditors requirements Automated Business Control Execution Testing Schedules with automated notification & testing Real-time monitoring & alerts for testers and Mgmt Evidence Collection & audit trail Dynamic Risk and Business Control Monitoring Key Performance & Risks Indicators Dashboard (+ mobile) Audit Support Combination of Solution, Libraries and Services 18 19 Segregation of Duties (SoD) The key pains & challenges: Now a Critical Business Control for ALL organizations Involves large volume of data (i.e. Typical = 200,000+ authorizations in Baan alone) Need to be done across Systems (ERP) and for ALL access types Is a recurring process due to constant changes The proposed approach & resolution: Automation, automation and automation! Cross-Applications ERM & SoD Business Processes & Controls Integr. Compliance Mgmt Business Risks SoD Mgmt Documents Business Controls SoD Conflict Rules Applications SoD Business Conflicts Access Mgmt Employees User Roles Process Diagram Documents Document Mgmt Conflict Resolution EZ-Compliance SoD Scan Mapics Hyperion BPCS … Network Access Facility Access Security Badges … Mapics Ceridian … Master SoD Matrix 24 Over 400+ SoD “zones” to be validated 25 The LN / Baan SoD Rules Library Introduced in 2005 Required 2 years initial development, and is updated regularly Content and design validated by CFO, Controllers, SOX Senior Consultants, Baan Specialists, etc... Covers all Baan versions (Triton, Baan IV, ERP-5, LN) Compliant to Baan Tools and DEM authorizations Verify 22,000+ Baan session combinations for SoD violations (with violation rating) to validate 400+ SoD sensitive “zones” Auditors such as E&Y, KPMG, D&T, PWC, Grant Thornton validated the Baan SoD Rules completeness and accuracy by successful certifying all EZ-Compliance clients to be SoD/SOX compliant. 26 EZ-Compliance Automated SoD Scan Import Employees LDAP (1) Access Scan Employee / Applications Access List SoD Conflict Rules (2) Conflict Scan SoD Library Oracle SOX – SoD Conflicts List Roles DEM Import Visio Business Processes SoD Resolution Rules Business Controls Mitigation Controls Import ERP Corp-wide Applications Business Risks Resolution (3) Scan Mitigated Conflicts List SoD Conficting Areas Matrix Click to view detailed business functions & conflicts found 28 The automated SoD cycle ERP Import Import of updated authorizations from all Enterprise Applications Investigation, resolution and mitigation of SoD risks Weekly or Identification of SoD conflicts & related business risks Daily Notification of new conflicts to internal audit team and/or process owners Resolution of conflicts with known patterns Result: 90%+ reduction of effort & cost How DynaFlow supports SoD Access/Authorization Mgmt Cross-systems authorizations (who is accessing what?) Periodic Access Reviews SoD Conflicts Identification Detective validation (what accesses constitute risks?) Preventive validation (what is the impact if we change …?) SoD Conflicts Resolution Automated resolution/mitigation using pattern rules SoD Conflicts Monitoring & Alerts Self-generated SoD Matrix with dynamic alerts Key Performance & Risks Indicators Dashboard (+ mobile) 30 Segregation of Duties (SoD) What you gain with DynaFlow: Cross-ERP Integration (SAP, Oracle, Baan, Mapics, ...) Bottled Best Practices: Fully automated Segregation-of-Duties (SoD) Rules Pre-Defined SoD Libraries available for Baan, SAP, Oracle, etc... In line with external auditors to secure successful certification Detective and also Preventative Fully automated SoD validation 90% reduction on implementation cost & effort 50% reduction on auditing cost 100% Successful SoD Audit Simplified insight in all user authorizations 32 Integrated Cycles Define Capture Document Process Knowledge Optimize Validate Objectives Action Metrics Integrate Structure Publish Measure Monitor Execute Publish Analyzes Review Certify Control Activity Regulations (eg. SOX, ISO, ITAR AS9100, HIPAA, ect) Risk Assessment 33 Route Definition Control Environment Automate Workflow Automation Measure Optimize DynaFlow Value Proposition Define Capture Document Optimize Validate Objectives Route Definition Integrate Structure Publish Action Measure Monitor Execute Optimize Automate Publish Analyzes Review Certify Risk Assessment 34 Control Activity Control Environment Measure BPM Reporting DynaFlow Solution Overview Management Dashboard Employee Process Dashboard Modeler and Auditor Dashboard Process Optimization & Monitoring Dynamic KCI & Issues Escalation Dynamic KPI & BI Analytics Process & Knowledge Publishing Business Controls Checks Automated Alerts & Notifications Process Modeling Business Controls Definition Process Automation Base Financial (Oracle, etc) Transaction Systems ERP (SAP, Baan, Mapics, etc) Office Apps (MS, Email, VPN, etc) Critical Capabilities Definition ERM & C Audit Management Supports internal auditors in planning and scheduling audit-related tasks, time management, managing work papers, risk assessments, control testing, remediation management and reporting. Risk Management, General Supports risk management professionals with the documentation, workflow, assessment and analysis, reporting, visualization, and remediation of risks. Analytics are mostly qualitative with a limited loss event analysis capability that is not dependent on stochastic analysis. It does not include stochastic analysis, but it may collect data from stochastic risk analytics tools to provide a consolidated view of enterprise risk management. Risk Management, Stochastic Involves stochastic analysis, such as Monte Carlo simulation. Examples include banks that require highly specialized capabilities for Basel II capital calculations and companies that must support project risk assessments of long-term asset investments, such as mining and oil and gas. Only a few EGRC platform vendors directly support these stochastic analysis needs organically or through an OEM partnership. Compliance Management Supports compliance professionals with the documentation, workflow, reporting and visualization of control objectives, controls and associated risks, surveys and self-assessments, testing, and remediation. At a minimum, EGRC management not only will include financial reporting compliance (Sarbanes-Oxley compliance), but also can support other types of compliance, such as ISO 9000, Payment Card Industry, industry-specific regulations, service-level agreements, trading partner requirements and compliance with internal policies. Policy Management Includes a specialized form of document management that enables the policy life cycle from creation to review, change and archiving of policies; mapping of policies to mandates and business objectives in one direction, and risks and controls in another; and distribution to and attestation by employees and business partners. GRC Content Includes many different kinds of content relative to GRC activities. Examples include regulatory analysis and news feeds, standards and frameworks, draft testing and risk assessments, and draft policies. Business Analytics Supports the ability to analyze the impact of risks on business objectives, performance and processes. 36 Gartner, Inc: 30 November 2010/ID Number: G00208665 DynaFlow simplification Regulations Implementation Framework Policy & Procedure Implementation Evidence Collection Business Risks Business Risk Libraries SOX HIPAA BASEL II COSO-II Business Control COBIT Libraries ...... Etc. Cross-ERP Integration People & Processes Mapping Compliance Business Controls: Program Mgmt. - Information delivery - Resource acces and use Compliance - Risk mitigation Change Mgmt. - ... Compliance Mgmt. establish Issue document test Web Portal Demonstratiopn of Compliance Demonstratiopn of Compliance Demonstration of Compliance Document Mgmt. Audit Trail Compliance Access &SoD Mgmt. Technology Facilities Operational Risk Monitoring Audit eBook Generation Data 38