To kick off our month of success stories, I wanted to start by introducing our policyIQ community to the team at Phelps Dodge International Corporation (PDIC). PDIC is a manufacturing organization, creating high quality wire and cable products throughout the world.
Spinning off and taking policyIQ along for the ride
In 2007, the PDIC division was spun off of another one of our policyIQ clients and was acquired by General Cable. When spinning off from their previous parent organization, the team at PDIC decided to continue the use of policyIQ to manage their Sarbanes-Oxley content. They were able to hit the ground running by bringing over many of their existing Risks, Controls and Test procedures directly from the existing policyIQ site of their then parent company, without having to re-implement or re-invent the wheel.
Standardize and streamline to build efficiencies across the globe
In 2007, I was introduced to Gaylord Haas III, the Director of Compliance, Risk Management and Treasury. Mr. Haas was responsible for the management of the SOX documentation and testing for PDIC, among an impressive list of other responsibilities. With locations all over the world, he found himself challenged by each location’s minor differences in documentation and processes – and he set out to streamline and standardize across every location.
We started by identifying the “best” process – the process that should be used by all locations across the world. While it was a great benefit to start with the content in the previous parent company site, it was also necessary to revisit the structure – including the organization of content and the fields that were used to capture data – to be sure that it was in line with the new spin-off organization.
With a solid structure in place, the actual Risks and Controls were the next focus of review. By travelling to many of the locations personally, Mr. Haas was able to gather all of the location-specific documentation and truly understand any real (versus perceived) differences in the procedures.
While some differences still remain, Mr. Haas was able to identify a standard set of Controls for all locations, now documented in policyIQ and organized by Business Process. Controls that might be unique to a specific location are also documented within each Business Process and identified as such by a naming convention that adds a unique country code. For example, “AP-12: Three Way Match” identifies a Control present at most locations, while “AP-12-ZA: Three Way Match” identifies one that is unique to Zambia.
Making your locations self-sufficient
In addition to streamlining the Controls, Mr. Haas also set about training each location to be more self-sufficient with their documentation of Testing. Controls are tested monthly, quarterly or annually at each of almost 20 different locations. By identifying the right individuals at each location, the team at PDIC has been able to assign testing out at each location and report on the status of testing at any given time. While Controls are now standardized and centralized, the testing process has been truly pushed out to the front line across the world.
Continue to expand and continue to bring on the best and the brightest
While PDIC continues to acquire new locations, each location is brought into the Sarbanes-Oxley process in roughly the same way. The standard set of Controls are reviewed and any customized Controls can be documented, if necessary. A new folder is created and a new group is added to accommodate the new location. Test pages are created for every Control at the new location, and the appropriate individuals are identified and trained to complete the testing. (Five new locations have been added since the start of the streamlining process.)
Earlier this year, Mr. Haas introduced the policyIQ team to Ms. Viviana Valentini, the new SOX Manager hired by PDIC to take on the management of the SOX process. Almost immediately, Ms. Valentini picked up where Mr. Haas left off – building additional efficiencies, considering on-going training for users and making the process as simple as possible for the individuals tasked with testing and documentation at each location.
We asked Mr. Haas and Ms. Valentini to summarize their experiences with policyIQ: “Having policyIQ as the mechanism used to document the testing results of PDIC’s SOX Controls for all of the various locations around the world has been a great tool which is constantly assisting us to manage and coordinate the testing that is taking place simultaneous in all of our different locations. policyIQ is our device used to evidence, document and improve our control environment in a timely manner.
Do you want some help to streamline your own set of Controls worldwide? Contact us and we’ll put you in touch with the experts in your area that can help you reach your goals!