Can your organization provide evidence that your house is in order?

Actions by the U.S. Securities and Exchange Commission (SEC) have amounted to more than a billion dollars in disgorgement, fines and penalties every year for nearly two decades. On average, nearly a quarter of actions filed also included named individuals as defendants. What does it mean for your organization if one of your employees engages in illegal activity? Well, that depends. Can your organization provide evidence that your house is in order?

The executives who sleep well at night know that 1) they have policies in place, 2) they have and enforce a process to ensure policies and procedures are kept up to date, and 3) the organization has gone to great lengths to ensure that all employees and third-party agents of the company are aware of the policies and procedures.

Upon request, managers in their organizations can provide the latest policies, proof of maintenance, access to previous versions, a list of all changes including who made them and when, as well as evidence of employee notification and certification.

Employees in these organizations can also rely on their policy management systems to help them work more effectively and efficiently. Their policies and procedures are appropriately linked to related regulations, risks, controls, and principles, and they include ties to responsible parties, departments, relevant locations, and systems touched. If a new employee, system, or regulation is introduced, they can see who and what is impacted.

The most adept organizations have a broadly communicated philosophy regarding policy documentation and practices that provides a shared foundation for all divisions, departments, and regulatory management teams throughout the enterprise. They utilize a centrally accessible policy management platform that supports collaborative authoring and monitoring while also providing all employees with easy access to the latest approved versions.

How well have you been sleeping? Reach out to us and soon you can rest, too, knowing your house is in order: 412.263.3330.

What comes to mind when you hear “digital evidence”?

Who cares?

I mean, who actually has to care about digital evidence? Consider the audiences or different roles of people who need to produce or rely on digital evidence: management and business unit leaders; auditors; information management, technology, compliance, and security professionals; and the officers of your organization. We are producing unstructured data, much of it valuable, at a breakneck pace. Do you know who your producers of quality digital evidence are?

When I hear digital evidence, I think of the artifacts that may be considered digital evidence such as raw data, reports, signed documents, test results, specifications, and performance receipts. Documentation of activities that provide assurance, including procedures, work instructions, training sessions and materials, and attestations are also critical. Have you identified which practices and assurances are closest to your significant accounts, risks, and controls?

How do we wrap our arms around digital evidence?

There are systems and practices that provide the bookends for ensuring relevant and reliable results contributing to digital evidence such as systematic management and monitoring of workflow, milestones, deadlines, analyses, and remediations. Digital evidence also relies on the trail of bread crumbs that show who touched what and when including the audit trail of changes, versions, handoffs, and approvals. Without a central portal or system in place, it is plain to see, we cannot reliably manage digital evidence.

Are you taking advantage of all that policyIQ has to offer in these areas?

Alerts, dashboard notifications, and email generated systematically by RGP’s policyIQ helps employees know when work is required of them. The taxonomy of the digital content is configurable and can be subject to the information governance preferences of your organization with appropriate read, write, and approve rights established during initial configuration. policyIQ can provide an enforceable framework to manage contributions, the complete capture, monitoring, and reporting on critical documentation and evidence.

If your opportunity has more to do with the quality of your existing evidence or the need for corroborating evidence, RGP’s subject matter experts can help to assess your need and to fill any gaps identified. Right now—whether related to technology, process, quality, or completeness—make a note of some of those gaps or pain points that just crossed your mind. And then reach out to us: Information@policyIQ.com; 412-263-3330.

5 Simple Steps to GRC Technology Implementation

Whether for IT Security Compliance, Enterprise-wide Policy Management, Contract and Lease Administration, your organization’s GRC or Audit program, policyIQ can be up and running in 5 simple steps. Read on for more information and contact us to automate your initiative in Q1!

Step 1: Configuration
A policyIQ expert will assist you and/or your RGP Consultant to customize the design of the user interface in policyIQ for input of data, navigation, reporting, content and user security based on your input and feedback. Of course, we do not progress to step 2 until you, the client, approve of the configuration.

Step 2: Prepare data
RGP Consultant requests data from your team or organization, then scrubs provided data to help ensure completeness and accuracy. You give approval regarding the condition of the data before progressing to step 3.

5 Simple Steps to Go-Time!

Step 3: Populate
RGP Consultant populates approved data (import or authoring, depending on your needs) and subsequently validates the completeness of what is in the system to the approved data. The RGP Consultant will provide you with a walkthrough of your site and data for feedback and your approval.

Step 4: Refine (Reports, Dashboard, Planning for roll-out/training)
RGP Consultant demonstrates the policyIQ user interface using the populated data. You provide a live example of a transaction, and with your RGP Consultant’s side-by-side help, you drive the live example from input to reporting. Any additional configuration items identified during this process will be considered for further customization. You give the green light when you’re ready to go-live.

Step 5: Go live and train
Often there are a handful of “power users” who are expected to regularly participate in the process that is being automated using policyIQ. The RGP Consultant sits side-by-side with your power users, individually or as a group, to train on use of the software. Your power users will be directed to policyIQ’s written and recorded materials that you can leverage for your personalized procedural guide. Your RGP Consultant and the policyIQ support team are available onsite or remotely for any questions.

Our methodology your yours?
What initiatives or processes are you looking to digitize and manage more efficiently in 2019? Hit the ground running with RGP’s subject matter experts implementing our proven methodology in our technology or we can support your team to implement your methodology. What kind of support do you need? Contact us, information@policyIQ.com, and we’ll help you to get the ball rolling!

Fierce Competitors are Built on Strong Core Processes

If your goal is to be a fierce competitor and to protect and defend your organization against the never-ending barrage of risks and change, a great place to start is by strengthening your core processes.

Policy management is the backbone of successful and sustainable organizations.

What do you think of when you think of policies? Does your Human Resources department manage a set of company policies that you have to attest to annually? Maybe you recognize the fact that your organization has a password policy and a policy regarding the use of social media on company equipment and company time.

In our recent webinar with guest presenter Michael Rasmussen, we heard a whole host of examples and reasons why organizations should be concerned with policies. If, up until now, you have not been particularly concerned about the value of your organization’s policies, you might want to lean in and peruse these notes from the Blueprint for Effective Policy Development and Management session:

Raise your hand if you are aware of where to find your organization’s index of official policies representing all areas of your business. Mr. Rasmussen asked a similar question of his audience at a recent conference and just 2% of attendees acknowledged awareness of an index maintained at the enterprise level of the organization’s policies.

Only a very small number of organizations see policies as the critical documents that they are. Mr. Rasmussen noted that policies are often not given proper attention and are strewn about in various systems, websites, shared drives and so on. Employees don’t know where to go to find documents or whether the document they found holds the latest version of the policy. In our session, Rasmussen emphasized why employees and leaders should value policies and highlighted some examples of how policies are at the core of every organization’s critical work:

  • Policies are GOVERNANCE documents.
    • Policies are critical documents.
    • They help to set boundaries to reliably achieve objectives
    • Policies ensure consistent business behavior and transactions.
  • Policies are RISK documents.
    • The existence of each policy was preceded by the identification of a risk!
    • Still, many business leaders do not think of risks when they think of policies and many do not tie organization policies to risks.
    • Policies help to identify risks and control risks within certain boundaries.
  • Policies are COMPLIANCE documents.
    • Policies help us to act with integrity as it relates to
      • Regulatory requirements
      • Contract obligations
      • Code of conduct
      • Values and Ethics
      • Corporate social responsibility
      • And so much more

Policies are at the core of all Governance, Risk, and Compliance work.
If the advantages of effective policy development and management are not compelling enough to motivate your leaders to establish policies throughout the organization, this regulatory environment might force the issue. An evidence trail is critical in today’s regulatory environment. Policy management requires a complete system of record and an audit trail.

policyIQ provides company and division leaders with a highly adaptable technology for managing the full range of policy, compliance, and audit needs in one cost-effective platform scalable from specific regulatory environments and department functions to division business units and at the enterprise level. Maintaining a clear and defensible audit trail is paramount to the service and benefit provided by our GRC technology.

In part I of the policy management educational series hosted by RGP’s policyIQ team, Michael Rasmussen highlighted the considerations that are critical for development of a policy management strategy, the roles that contribute to policy management, and he drilled deep into the effective policy management lifecycle.

In part II, Michael will concentrate on the second half of the effective policy management lifecycle. The attendees of our first session gave rave reviews of the presentation. Be sure to register for Part II: Engage the Front Lines Through Effective Policy Communication.

We also encourage you to peruse upcoming events hosted by the policyIQ team. This audience, in particular, might be interested in our Introduction to policyIQ session that is delivered quarterly and demonstrates how organizations leverage policyIQ to establish consistent documentation templates, prescribe workflow and approval processes, communicate and distribute policies, monitor and enforce compliance with policies, and to establish a maintenance process for your critical documentation.

Click here to register for the sessions that interest you and we invite you to reach out to us (information@policyIQ.com or 866.753.1231) with questions about effective policy management, policyIQ (our governance, risk, and compliance technology), or if you could use the support and expertise of a RGP professional to help get your program off the ground.

We look forward to seeing you in future sessions!

A Remedy for Decentralized Audit Approaches

Is your organization still struggling with manual audit processes? Do you have audit projects, past audits, and workpapers strewn about in various shared network folders (or worse, on various hard drives)? Do your auditors have to rely on email to collaborate and share documents? How about your naming convention—has your audit group standardized the way that documentation is labeled to help you to keep the information organized and easy to reference? Speaking of standardization, have audit processes been standardized across the organization or does each location or division manage their own audit program? And what would you say about your review and approval process? Is it clearly mapped, followed, and approvals communicated? Are audit findings routinely rolled up and reported?

RGP’s policyIQ addresses each of these challenges so that you can realize more effective and efficient management of your organization’s audit function. Leverage predefined Templates, Folders, Workflow, Reports, and Audit Trail for your compliance, audit, or policy management documentation. It is also simple to customize the structure to accommodate ongoing changes or characteristics that are unique to your organization, program, or team.

Configuration adjustments are at your fingertips. You do not have to reach out to a support desk or technical team to add templates for specialized workpapers, IPEs (Information Provided by Entity), or for your PBC (Provided by Client) process. Adjustments can be made directly by users authorized in your organization. If you haven’t yet incorporated those templates into the flow of your work and want some help getting them set up, we do have support and configuration specialists who are happy to walk you through the setup of your custom program.

We expect all of RGP’s policyIQ audit clients to be enjoying these benefits in your audit program:

  • Consistent enterprise-wide audit process
  • Centralized access to workpapers and IPEs
  • Simplified administration of PBCs and audit process
  • Ability to easily locate and leverage audit templates/projects and previous audits
  • Streamlined communication among management, auditors (internal and external), and approvers
  • Real-time monitoring capability and status reporting
  • Simplified management and audit committee reporting

We’re ready to help you reach your goals!

Whether you are an existing policyIQ user or a new one, we want to help you to improve and automate your audit program. Perhaps you are new to the administration of your site or you are not sure how to make adjustments to the configuration of your site’s templates or structure. Reach out to us and we’ll be happy to help you get started or to optimize your implementation. Support@policyIQ.com.

7 Features to Boost Efficiency in Your Daily Work

In case you were out enjoying your summer and missed announcements on the latest policyIQ release, we’re here to share the highlights! The theme of policyIQ’s version 7.9 is Convenience. We rolled out 7 features that help to boost efficiency in the flow of your daily work.

  1. Navigation continues to get easier and faster! Save time by leveraging “Favorite Folders” to lift your critical work to the top of the list.
  2. Is yours one of the organizations that uses policyIQ primarily for Account Reconciliations, 302 Certifications, or Policy Sign-offs? Perhaps you’d like to have Form Management as your top navigation option? Site Administrators, you can highlight your prioritized activities that your organization engages in most by reordering items in the left navigation pane.
  3. Paste content into policyIQ from a range of other document and file types and retain your formatting with this upgraded HTML/Rich Text Editor.
  4. Perform calculations on multiple figures originating in related content (Calculated Linked Fields). This allows you to perform activities like determining cumulative risk calculations and arriving at the sum of Standalone Selling Prices for each Performance Obligation linked to the contract.  The flexibility of policyIQ to provide more custom solutions for a wide range of business initiatives just got a boost with this feature!
  5. Approvers – we’re thinking of you.
    1. Some people rely on email to keep them apprised when their attention is needed and others loathe the ever-growing number of items in their inbox. Now, policyIQ lets you decide which approvers in the approval string will be automatically notified via email when items have been submitted for their review.
    2. Prior to this release, an individual could only occupy one step in the approval process. It was not historically possible to approve, pass the content to other approvers, and then bring it back around for final approval. If a process requires the same person to step in multiple times, policyIQ now supports that process.
  6. Rolling forward just got easier! If your organization likes to leverage the previous period’s tests rather than starting from blank templates, you can accomplish roll forward in fewer steps with the ability to Remove Attachments in Bulk.
  7. Take advantage of the flexibility of policyIQ! Changes in process, regulation, org structure, or responsibilities might lead to the need for adjustments to solutions and templates. Solution designers (policyIQ administrators) will be happy to learn that it is now possible to copy fields from one template to another, making it easier to leverage the work of previous solutions for new or improved solutions.

Would you like some help taking advantage of features that were rolled out after your original configuration (from this summer’s release or past releases)? Contact us and we’ll be happy to walk you through the steps!

5 Steps to a More Efficient Internal Control Environment

Is your team overwhelmed with activities that feel unnecessary?

How confident are you that the energy spent on testing is focused on the necessary controls?

Leverage policyIQ to systematically focus on the critical controls for management and testing. More efficiently analyze which Financial Statement Assertions, relative to each of your 10K line items, are adequately controlled, which are left vulnerable and which of your relevant assertions is over-controlled! See, plainly, the gaps in your coverage and leverage the evidence to justify the reduction of waste, and plan to concentrate effort on work that matters.

This process really starts with your risk assessment. If you have not leveraged policyIQ to bring automation and reliability to your risk assessment process and want to walk through the policyIQ solution (including the just-released feature that makes cumulative risk calculations possible), reach out to schedule a free working meeting with us! After completing your risk assessment, identifying significant accounts and relevant assertions, and determining which of your processes and objectives are in scope (all steps that can be managed in policyIQ), you can begin the process of rationalizing your controls.

Next, leverage policyIQ to move through these five Control Rationalization steps:

Each step is made more efficient with policyIQ. We can support you to customize templates for the attributes that are critical and unique to your organization. The import, linking, calculations, workflow, and reporting features will allow you to more quickly examine the effectiveness and priority of your procedures. Having confidence in your Control Rationalization process and your internal control environment then allows you to come full circle to look at the bank of risks that you previously identified. You might conclude that some process risks that have consumed time and attention for years are actually not in scope. This Control Rationalization process will help you to be more effective and more efficient through each testing cycle.

Would you like to see sample templates and schedule a working meeting to get the ball rolling? Contact us and reap the benefits by your next testing cycle!

Not all roads lead to successful IPO

Welcome guest blogger, Jason Chiang. With RGP for nearly 8 years, Mr. Chiang has more than 20 years of experience and expertise in Audit, Risk and Compliance. He has consulted with a range of companies from financial services, biotech, manufacturing, healthcare and other industries. Mr. Chiang is a Certified Public Accountant (inactive) and Certified Internal Auditor. He has served on both sides of the house as a senior audit manager and senior auditor as well as a risk manager. It is evident that he understands the motivations and hurdles facing these organizations and approaches their complex issues with integrity and professionalism.

The following article was written by Jason Chiang (with editing support from Stephenie Buehrle). The approach and recommendations are his.


Not all roads lead to successful IPO

When a company approaches their initial public offering (IPO), it enters a very different arena. Having access to public funds, that is the retirement savings of Main Street USA, the company must meet quarterly SEC filing requirements. This is a significant amount of work. An investment in the people experienced with technical accounting, SEC financial reporting, and Sarbanes Oxley Compliance (SOX) evaluations combined with an investment in systems and tools to do the work efficiently and with completeness and accuracy is crucial to meet the filing deadlines.

One cannot audit all internal controls over financial reporting (ICFR). Thus, performing a SOX risk assessment is necessary to identify the significant accounts and their relevant assertions. If you happen to be one of these companies developing a road-map to your IPO, SOX may not be the place where you want to focus significant time and financial resources, but you realize that it has to get done. Be sure that you consider, at minimum, these critical components:

Risk Assessment                                  

A risk assessment is the process of identifying significant accounts and disclosures and their respective relevant assertions as they relate to financial statements. A properly done risk assessment will allow the company work smart by focusing its internal controls evaluation on the areas where there is a possibility of a material error.

The Risk Assessment must include:

  • Quantitative factors such as account balance, frequency of transactions, dollar value of each transaction; and
  • Qualitative factors such as complexity of related transactions, subjectivity of accounting rules over related transactions, and fraud considerations.
  • As business and risks change, the risk assessment needs to be updated.

Narrative                                                                

A narrative provides mid-level detail of the transactions and internal controls within a business process and includes who, how frequent, and in what location the transactions and controls are being performed. The initial creation of narratives provides the process owners an opportunity to revisit and reflect on the current processes, and make improvements for operational efficiency or control effectiveness. It is a written document that can be read by internal employees, internal auditors, and external consultants and auditors to gain a preliminary understanding of the process. As processes change, the narrative provides a format to document the change.

What critical things must be considered regarding Narratives?

  • The narrative should be written knowing that auditors will be a primary reader and will be looking for controls that mitigate risks.
  • When describing management review processes in the narrative, articulating how the manager gains assurance of the completeness and accuracy of the supporting evidence before signing off. If the manager is using judgment, describing the factors considered.
  • Narratives should be updated as changes are implemented in the organization. The updates should follow a workflow where there is a review process for significant changes.

Control Matrix                                      

A control matrix lists the controls the company has identified to mitigate risks. The control matrix serves as evidence that identified risks are mapped to controls which are to be evaluated for management’s assessment of internal controls. The control matrix also is a primary client document auditors leverage to perform their independent test of controls.

Take care to ensure that:

  • The controls in the Controls Matrix are mapped to risks.
  • The Controls Matrix is in a format where it is sortable or reportable by controls mapped to risks for test of controls purposes, and risks are mapped to controls for an evaluation whether risks are mitigated by controls.
  • Controls in the Controls Matrix should be labeled and provided an abbreviated title (10 words max) for ease of reporting and reference purposes.

Testing                                                                      

Testing is the evaluation of design and operating effectiveness of the company’s controls. The results of testing of controls provide company management with a baseline to that might have impacts to strategic and operational decisions. For publicly held companies, testing is an SEC requirement.

Critical considerations for testing:

  • Important, if deemed necessary, to be able to re-perform the actual control performed by the employee (e.g. for 3-way match of purchase order, invoice, and shipping docs, test that an employee had performed this and has evidence of such, rather than the auditor requesting the 3 docs and testing oneself).
  • When testing management review controls, cannot just accept sign-off, but need to understand the steps and judgments used by the manager, and test accordingly.
  • The documentation of testing should allow someone else to reasonably re-perform the testing. If testing is being relied upon by external auditors, then the breadth of documentation is more important. If not, not all needs to be retained, but should be readily retrievable when needed.

Certifications                                        

Control owners certify to the CFO and CEO that controls are operating effectively on a quarterly basis, and if not operating effectively, the remedial action plans. The control owners are held directly accountable for their controls as they are certifying to the top two officers of the company.

Recommendations for certifications:

  • The number and level of person certifying to the CFO and CEO should be carefully considered. The level should be their direct reports and one level removed to maintain the efficiency and integrity of the certification. If it is a larger organization, there can also be sub-certifications up to the senior manager level.
  • The certification questions should have a combination of checklist questions, as well as, open ended questions to encourage a thoughtful process.
  • Utilizing software for tracking, follow-up, and retention purposes is advised.

Depending on the number of people involved with the inputs into the various components, one might decide that performing and capturing the work in Excel is sufficient, while others might prefer utilizing a SOX tool where there are extra protections in version control while allowing multiple users to perform inputs simultaneously in multiple locations. A SOX tool may also provide management with options for review, analysis and oversight that are not available in Excel.

To avoid unexpected setbacks, be sure to plan enough time into your IPO readiness map for SOX evaluations. The initial SOX program development and implementation is likely to require six months and can vary depending on your access to subject matter experts. Coordination and alignment of the SOX efforts and objectives among the audit committee, senior management, process owners, and internal and external auditors is paramount for a successful implementation.


If your organization is approaching your initial public offering and you’re interested in learning more about how RGP can support you with subject matter expertise and a tailored technology solution to help ensure that you are prepared for your SEC filing and financial reporting requirements, reach out to us (Information@policyIQ.com, 412.263.3330) and we’ll connect you with our RGP colleagues near you!