The Gilbane Advisor

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Sarbanes-Oxley: Too Narrow?

I have been spending a lot of time with the Sarbanes-Oxley Act (SOX) lately — and have run across a really useful book. The title is Beyond COSO: Internal Control to Enhance Corporate Governance, by Steven J. Root (Wiley, 1998).

Yes, I know … the book predates SOX. When it was published, people were still talking about what a great company Enron was. Undergraduate accounting students were still hoping to land a job with Arthur Andersen. That is part of what makes the book useful.

As many of you probably know, SOX and the SEC don’t  prescribe just how a company must set up internal controls — the SEC only requires that you use a suitable, recognized control framework. In the final rule, the SEC points out that COSO — the framework developed by the “Committee of Sponsoring Organizations” of the Treadway Commision — is such a “suitable” framework.

What make’s Root’s book so interesting is that it is a critique of COSO.  At the heart of this critique is Root’s concern that COSO focuses too narrowly on controls to ensure accurate financial reporting, giving short shrift to the kinds of operational controls that often really make a difference between a business that succeeds and one that doesn’t.

When you look at SOX, you can take Root’s concerns and add an exponent.  Compliance with section 404 of SOX takes what little emphasis there is in COSO on matters other than financial reporting and discards it: 404 compliance is ALL about internal controls to ensure the accuracy of financial reports.

To be sure, accurate financial reporting is a good thing. But it is a rare CEO who decides that what it will take to make his or her company great is better financial reporting.  Improved quality, a stronger connection to the customer, returns exceeding the cost of capital — yes — these are things that management focuses on.  But, better financial reporting?

The sad thing is that improved internal controls really can improve quality, customer response time, and the decision making required to improve return on investment.  But a company that focuses solely on SOX compliance is going to miss these things.

Is this a topic — a concern — arising in your companies as you come to terms with SOX?

Anyway, take a look at Root’s book. It provides a historical perspective on SOX that is missing from some of the recent focus on “compliance.”

Taxonomies, Folksonomies & Controlled Vocabularies

There is an enlightening discussion going on between Lou Rosenfeld, Clay Shirky and others on the utility of folksonomies as used by Flickr and del.icio.us, vs. subject-matter-expert developed taxonomies. As one of the commenters has pointed out, this is not an “either/or” issue. Certain applications where the scope of the content and users is bounded will benefit from the discipline of a carefully architected vocabulary. Other applications where the scope of either the content or the user community is less well-defined will either suffer or, more likely, the users will ignore the prescriptions (this is why the “semantic web”, if I understand it at all, is hopeless). The key issues are related: cost and adoption (cost is usually a function of adoption, not development), and I think they both would agree on this point. How these approaches might work together is trickier and well worth exploring. In any case, this debate provides a condensed lesson in many issues that most enterprise content managers have probably not thought through, but even those that have should check out this thread.

Software AG to Acquire Sabratec Ltd.

Software AG plans to acquire Sabratec Ltd. for its ApplinX legacy integration technology. The combined capabilities of the two companies will provide customers with the ability to integrate virtually all of their mission-critical legacy applications with the newest business architectures. The ApplinX product is synergistic with Software AG’s Enterprise Transaction Systems and XML Business Integration portfolios. The ApplinX technology focuses on helping mainframe customers with applications written in COBOL to cost effectively extend those applications to other business systems. As part of the agreement, Software AG will acquire Sabratec’s Israeli headquarters as well as Sabratec, Inc., located in New York. In addition, Sabratec’s partners in 14 countries worldwide will be able to offer the full line of XML-based integration solutions from Software AG. www.softwareag.com

XML and Electronic Forms

I haven’t updated my eForms Resources page in a while, and I should, as there has been a lot of news lately, including the introduction of Acrobat 7 and Adobe’s recent announcement of their LiveCycle Policy Server.
I spent some time today at the formsPlayer Web site. formsPlayer is the XForms technology from UK-based x-port.net Ltd. They have a complete toolkit for developers, but you can also download the player itself for free, and then they have a nice set of example XForms, including ones that combine XForms with SVG.
The installation of formsPlayer requires IE 6, and the latest version of the Microsoft XML parser, but the installation will prompt you for this.

Workshops for San Francisco Conference

Thinking ahead to San Francisco, we would like to get some input on topics for workshops. In Boston, we had three post-conference workshops:

  • Web Content Management Systems: Principles, Products & Practices
  • Content Technology Choices for Technical Communicators
  • Enterprise Search – Principles, Players, Practices, & Pitfalls

There’s room at the San Francisco conference for additional workshops, and a few potential topics come to mind:

  • XML and Content Management
  • XML-Based Electronic Forms, to include InfoPath, Adobe eForms, and XForms
  • Content Security, to include Digital Rights Management, Policy Management, and Compliance and Governance
  • Understanding and Using the Darwin Information Typing Architecture
  • Taxonomy, Categorization Tools, and Information Architecture
  • XSLT, XSL-FO, and other Technologies for Content Transformation
  • Digital Asset Management State of the Art and Market Snapshot

What would people like to see? Please weigh in with preferences and ideas. I am going to look for some kind of online polling device and will look to post a poll based on some initial feedback.

Hot Topics for Life Sciences Industry

The Drug Industry Association (www.diahome.org) has invited me to deliver the keynote address at its 18th annual electronic document management conference in Philly on Feb 16. I’m interested in opinions and insights regarding hot topics that keep content professionals in pharma awake at night.

Mediasurface & Cervalis to Provide Hosted Content Management

Mediasurface announced that it had entered into a partnership agreement with Cervalis, a managed service and hosting specialist. The new service allows companies to deploy the Mediasurface solution in a fully hosted environment, taking advantage of Cervalis’ enterprise class security and scalability with an extremely low set up and maintenance cost. www.cervalis.com, www.mediasurface.com

Adobe Announces Acrobat 7.0 Software Availability

Adobe Systems Incorporated announced the immediate availability of Adobe Acrobat 7.0 software. Acrobat 7.0 provides users the ability to assemble documents from multiple sources, create intelligent forms, and collaborate on projects inside and outside the firewall. The Acrobat 7.0 family offers different functionality to address specific customer workflows. Acrobat 7.0 Professional provides more advanced control over engineering and design documents for technical and creative workgroups that rely on specialized software, including computer-aided design applications and publishing solutions such as Adobe Creative Suite. Acrobat 7.0 Standard is for business professionals in organizations of all sizes. Acrobat Elements is a license-only product that allows enterprises to put Adobe PDF creation capability on every desktop for more secure document distribution. Adobe also announced the immediate availability of Adobe Reader 7.0, including a public beta version for the Linux operating system. Adobe Reader 7.0 now offers the ability for users to participate in document reviews, have Yahoo! Search capabilities at their fingertips and interact with 3D objects placed in PDF. Acrobat 7.0 Professional and Acrobat 7.0 Standard for Microsoft Windows 2000 (with service pack 2), Windows XP Professional, Home and Tablet PC Editions, and Mac OS X v10.2.8 and v10.3, are immediately available in English. French, German and Japanese language versions are expected to be available in early 2005. www.adobe.com

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