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Tuesday, June 30, 2009

C-SOX: 4 tools you need to know about

China SOX will have a radical impact on the Chinese business environment. The Standard will require a new approach to risk management, internal control, and communication with all company stakeholders. The IT department will play an important role in driving C-SOX compliance.

Lots of IT systems that support an enterprise, from email to ERP to financial systems. This post will quickly look at a category of high-impact technologies that are not currently widely used in corporate China.

These include:

1) Document and knowledge management. Hundreds of internal control documents are created during a C-SOX implementation project. These documents cover the processes, procedures and policies of all areas of the company and become the foundation for the internal control system. Therefore, it is critical to have a document management system in place that allows for the centralized creation and management of this information. The document management system includes authoring, review, approval, publishing, editing, version control and retiring documents.

2) Employee performance management. Company management has to set internal control objectives and manage them throughout the year. A performance management system should be used to record, manage and report on the goals and objectives that are set by the company. There are three main parts to a performance management system: defining, managing and reporting on the goals.

3) Testing and Assessment tools. C-SOX compliance involves aligning operations to be predictable, consistent and validated. By implementing and maintaining a testing and assessment management tool, an organization can accurately track and report the state of compliance and respond promptly to requests for C-SOX compliance audits.

4) Online learning. E-learning is a great opportunity for companies to save time and money in their C-SOX implementations. Online courses are high-quality, interactive tools that can provide multiple business benefits to companies who are use these tools.

These technologies are “high impact” because they are generally deployed widely across the organization and are used frequently by employees. They are not as complicated or as costly to implement as other enterprise systems. Finally, they can be used together as a suite to accelerate China SOX compliance.

We just published a detailed white paper on these technologies, which is available on our website. Click to learn more about China SOX compliance tools.

Wednesday, June 24, 2009

China SOX: Top 10 Business Benefits of Compliance

Executives often grumble when new government regulations, like China’s Basic Standard for Enterprise Internal Control (C-SOX), are released. They're concerned about the extra time and cost of implementing the rule and the burdens that this will place on the company and its staff. While compliance with government regulation can be costly, what about the benefits? In China, where corporate governance and risk management practices are generally behind those in Western countries, companies can expect significant benefits from implementing this new regulation.

1) Reduce risk. When employees are more aware of how to manage and prevent risks, the overall risk profile goes down - this includes financial and operational risk categories.

2) More predictable business. Companies that have steady, predictable business are valued more highly by investors, customers and partners. China SOX compliance makes you more predictable by imposing discipline.

3) Trust. Investing in the process of C-SOX compliance means that the market will perceive your company as more trustworthy because you are willing to make your operations more transparent.

4) Higher stock price. The stock market values companies that are well-disciplined and transparent higher than companies that are difficult to understand. Companies that are C-SOX compliant will have higher valuations than those which are not. This data has been validated in the US and Japan, which have similar compliance rules.

5) Motivated employees. Employees care that the companies they work for are ethical, well-run and stable. Therefore, investing in China SOX compliance means that your workforce will be more motivated to help achieve your goals.

6) Lower employee turnover. The average cost of replacing an employee is 150 percent of the employees annual salary. Therefore, there is a big incentive to reduce turnover and lower your costs. Companies that are C-SOX compliant have better processes and more engaged employees, which will reduce the voluntary departure rate.

7)Improved supplier relationships. Suppliers are a critical part of your supply chain, and they will appreciate your investments in processes and systems that give them a clearer view and more access into your business. This means more just-in-time delivery, lower inventory costs, and more bargaining power with your vendors.

8) Faster decisions. C-SOX mandates the definition and documentation of internal controls and company policies. This means that information will be easier to find and use, and that the company will be able to make decisions more quickly.

9) New customers. China SOX compliance is a competitive advantage and customers will want to do business with a company that is open, ethical and well-run company. Expect to see higher win rates and more profitable customer relationships once you have started your implementation.

10) Improved corporate governance. This is the sum of the benefits of compliance. Better corporate governance lowers risks for all stakeholders, improves the image of the company, allows for better decision-making and more efficiency in the company. This will be reflected not just in the board of directors, but in all employees.

Evidence from companies that went through the Sarbanes-Oxley (SOX) implementation process in the US (including several Chinese companies) tells us that there are more operational, financial and strategic benefits from adhering to good risk management and disclosure practices. Since the Basic Standard for Enterprise Internal Control is bringing valuable concepts to China, the rate of improvement for many firms will be dramatic.

Wednesday, June 17, 2009

How to Improve Corporate Governance in China with Online Training

With China’s Basic Standard for Enterprise Internal Control (C-SOX or “China SOX”) coming into effect soon, many companies in China are struggling to develop an appropriate training plan for how to educate their workforce about this new rule.

The biggest challenge for companies adopting China SOX is to improve their corporate governance. For China SOX to really succeed, companies have to embrace sound corporate governance as a concept and adopt it as a business strategy.

Training programs are needed to help drive the corporate governance principles mandated by the Basic Standard for Enterprise Internal Control. But given the complexity of corporate governance and its many aspects, where should companies start?

Online training (e-learning) is a powerful tool to improve corporate governance. Here are 5 ways that e-learning can help improve corporate governance and lead to China SOX compliance:

1) Good content.
Start with relevant content developed by corporate governance experts. The courseware should be relevant to Chinese companies and provide an overview of the main benefits and implementation strategies of good corporate governance. Users should be able to take the e-learning course at their own time and at a reasonable length (a best practice is to break up the courses into 10 – 15 minute modules).

2) Segment your user base. With e-learning, you can provide targeted information to specific users. The benefit of this is that you can provide exactly what the learner needs, no more and no less. Considering the complexity of corporate governance, many employees just need to know the basics. However, top managers will need much more detail on how to implement corporate governance principles.

3) Delivery system. Use a learning management system (LMS) or similar tool to deliver the content to your users. That way, it is easy to track and manage and the training can be centrally administered, no matter how large and dispersed the organization. In addition, the LMS can be used as a communication tool and document repository.

4) Reporting. Unlike traditional classroom training, powerful reports can quickly be generated from e-learning. This helps for analysis and evaluation of your training results, ROI and reach. Detailed analytics are possible once you have done the training several times and can match it up against business results (in this case, compliance with China SOX).

5) Cycle as needed. Training is only effective if it is reinforced over time. Online learning means that you can provide reinforcement in small amounts to your audience to make sure they are keeping up. The marginal cost of additional training is basically zero, which makes it much more cost effective than traditional instructor-led training.

More corporate governance e-learning courses.

Monday, June 8, 2009

The Most Important Criteria for China SOX Success

China’s Basic Standard for Enterprise Internal Control (C-SOX) is coming into effect soon, and while some of the implementation guidelines are not yet clear, the core of the regulation is in place.

The purpose of C-SOX is to increase the effectiveness of internal controls in listed Chinese companies, thus reducing risks for companies and their stakeholders. Companies must evaluate their internal controls, publish an evaluation report on an annual basis and audit the effectiveness of their internal controls. These are new concepts to many organizations in China, and as a result there is some resistance and confusion to deal with. Many Chinese companies have poor risk management systems, inadequate business data and patchy IT infrastructures. However, these are not the biggest challenges facing companies that will be required to comply with C-SOX.

The biggest challenge (and hence, the top criteria for success) is company culture. No amount of money, software or consultants can compare with the beneficial effects of enlightened and committed management. For C-SOX to really succeed, companies have to embrace risk management as a concept, adopt internal control frameworks and change their corporate culture.

What does that mean? For organizations to get the most benefits of C-SOX compliance, they must:

- Foster openness and transparency in the company
- Be open to self-evaluation and self-criticism (of the management team and all employees)
- Report on perceived risks in a timely fashion
- Provide training on the benefits of risk management and internal controls
- Have executives visibly “own” the C-SOX implementation
- Establish a “whistleblower” mechanism and fraud reporting hotline to alter the company to potential problems

Management will need to be visible in its support for C-SOX and ensure that a sense of urgency is felt across all offices and regions. This means creating a project team with adequate representation from the entire business, and one with the political clout required to overcome institutional resistance to change.

Although responsibility for risk management and compliance ultimately sits with the CEO and Board of Directors, forward-thinking companies will move to push responsibility to various parts of the organization. C-SOX projects require participation from many levels of an organization, and for compliance projects to succeed, companies must make their staff an active participant on the integrated project team.

Industry leaders involve much of the organization in their C-SOX implementation process and go beyond the minimum requirements imposed by the Basic Standard for Enterprise Internal Control to improve operating results while introducing business improvements throughout the organization.

Many companies in China do not currently have this kind of culture, and that is going to mean extra time and effort and required for proper implementation of the Basic Standard for Enterprise Internal Control. Companies that see this as an opportunity to refresh and improve their corporate culture will be rewarded with a quicker process and more tangible business benefits.

Friday, June 5, 2009

10 Questions to ask Before Starting Your China SOX Compliance Project

China’s Basic Standard for Enterprise Internal Control (C-SOX) is coming into effect soon, and while some of the implementation guidelines have not been specified, the core of the regulation is in place.

The main purpose of C-SOX is to increase the effectiveness of internal controls in listed Chinese companies, thus reducing risks for companies and their stakeholders. Companies must evaluate their internal controls, publish an evaluation report on an annual basis and audit the effectiveness of their internal controls. These are new concepts to many organizations in China, and as a result there is some resistance and confusion to deal with.

Below is a list of ten questions to address before starting your C-SOX implementation process.

1) Do we have an organization map? This document is the backbone of your C-SOX implementation because it shows the roles and responsibilities for the departments and employees. It will be used to assign areas of responsibility and internal control approval levels. If your organization does not have a recent map, work with your human resources department to put one together.

2) Who “owns” C-SOX? The answer should be the CEO and Board of Directors. If top management doesn’t own the C-SOX process, it means that the company is not putting in the right amount of resources needed to make the implementation work. Companies that delegate C-SOX implementation to a specific department risk failure due to lack of support.

3) What is our current risk management framework? An existing risk management framework is a great starting point for C-SOX. It could be based on COSO, ERM or ISO 31000 – the point of departure is less important that the discipline that comes with a risk management process. If you do not have an existing risk management framework, you should hire an outside consultant or expert to help you.

4) How will IT help us? IT will play a key role in your C-SOX process, so it helps to get the IT team involved early. Part of the implementation will be buying new software (in fact, the Basic Standard for Enterprise Internal Control mandates the use of IT systems with in-built controls) and the IT department can help to draft a strategy and execute it.

5) What is our training plan? Your compliance initiative will not succeed if you don’t train your staff. The training plan should include at least the following elements: why internal control is important, key internal controls, company policies and procedures, and who to go to with questions. Use e-learning to get the training out quickly and with maximum consistency.

6) Where is the expertise? If you don’t have experts on internal control and risk management within your company, you should hire externally to jump start your project. There are many specialist consultants who can help you develop and execute your strategy and who will train your staff (this will reduce your costs in the long term).

7) What constitutes success? Make sure the CEO and top management have a shared vision of what C-SOX success looks like. This is a long process and there will be many steps along the way. Your implementation plan should detail key milestones and metrics for your business.

8) How do we evaluate staff performance? Several elements of C-SOX are related to human resources. Managers have to perform self-evaluations against internal control metrics, meaning that department managers will have to disclose information about their goals and objectives, and rate themselves on their performance. Furthermore, the Basic Standard for Enterprise Internal Control requires that compensation of executives be linked to internal control. These are new concepts for many companies, and setting up a performance management process is the best way to implement these requirements.

9) What’s in it for me? Unless managers understand the benefits of C-SOX compliance, they are not likely to want to invest time and money in the process. Make sure you have an education campaign so staff understand where they fit in the process and the benefits to them.

10) What’s next? C-SOX compliance is an on-going process, not a one-time event. There are always next steps and future plans and strategies that need to be implemented. You need a team that is able to implement existing requirements and plan ahead for what comes next.

The Basic Standard for Enterprise Internal Control is a wide-ranging rule which will impact every area of a company’s business. You need to take care to address these fundamental questions before starting your implementation process.

Click for more C-SOX. Chinese version of our China SOX solution.

Thursday, June 4, 2009

7 Tips for CFA Success

Your chances of passing the CFA Level 1 exam on the first attempt are about one-in-three. That number is even less if you are not a native English speaker or if you are taking the exam outside of the US or Western Europe. Here are seven simple steps to follow to give yourself the extra boost you need on test day.

1)Pace yourself. Study at your own pace and don’t be rushed. One of the big drawbacks of CFA preparation classes is that you have to proceed at the pace of the group and this may be too fast or too slow for you. Far better is to be able to use reference materials and online learning and study at your own pace, free from distractions.

2) Use available free tools. There are lots of free test questions, background guides and other resources available that can help you prepare. Many providers of online courses (such as Vast Talent and KESDEE) will give you a free preview so you can try their products before you buy.

3) Take practice exams. The best way to get familiar with the test (and the pressures of test day) are to practice, practice, practice. That means doing exam questions all the time (before bed, on the bus, during a break at work) so you become familiar with the wording and style of the questions and you are able to work more efficiently on test day. Even better is to take one or two full length, timed tests in the month before the exam to give you a feel for the pacing and time pressure on the exam.

4) Keep up-to-date. Read the newspaper and financial journals (like the Financial Times, Economist, Business Week, Wall Street Journal, CFO Magazine, etc) to stay abreast of trends in the marketplace. Not only will you learn a lot about what’s going on in the world of finance, you will also come across handy references pieces to help you with the exam.

5) Get a good night’s sleep. Far better than cramming on your last night is to make sure you are well-rested. Your brain will function better on a good night’s sleep and you will appreciate it during the (long) day. You are going to need lots of stamina to finish both sections of the test, so get your beauty sleep.

6) Arrive early. There is nothing worse than being stressed during the test, to make sure to arrive at the exam site early (most open several hours before the exam begins and will let you in up to an hour before start time), scope out the room and get comfortable. There are restrictions on what you can bring into the test site with you, but arriving early will allow you to mentally prepare yourself.

7) Skip questions. Don’t get caught up on a question you know you can’t answer or that will take you too much time. Since you have to answer lots of questions in a specified period of time, you are better off skipping questions you struggle with and going back to them at the end (time permitting).

Good luck! Read more about our CFA Prep course.

Tuesday, June 2, 2009

Internal Control Conference in Beijing

There's a conference on China’s New Internal Control Regulations organized by CCH coming up next week (June 11) here in Beijing.

For an overview of the conference, see the CCH website and the event brochure can be found here

The speakers are partners from PricewaterhouseCoopers and it isn't clear from the brochure if any representatives from the Chinese government will be addressing the session.

Latest Changes to China SOX

The Chinese government has announced some additional changes to the Basic Standard for Enterprise Internal Control that impact the initial scope and audience for the regulation.

I mentioned previously that we are looking at a six month implementation delay (moved from July 2009 to January 2010). It now appears that some of the regulations may be relaxed and that the first wave of impacted companies will be Chinese firms listed overseas and state-owned enterprises.

See this article (in Chinese) for more detail: http://www.cnstock.com/paper_new/html/2009-05/06/content_69600302.htm

None of this is yet official, so I am keeping an eye on the developments. The potential impact is that listed companies will now have time to learn from the experiences of the SOEs (who will presumably receive some guidance from the Ministry of Finance on how to implement C-SOX).

Get the latest China SOX resources from Vast Talent
, including our new whitepapers.

New White Paper Available

We just launched a new white paper, Getting a Head Start on Your C-SOX Compliance Project, on the Vast Talent website. You can download a free copy at our China SOX Resources page.