Published on May 15, 2008
Surviving Sarbanes Oxley: Emerging Practices & Pitfalls Tony Bennett 8th February 2005
• Introduction • Impact of s.404 • Approach to s404 • Pitfalls / Lessons learned • Recurring SOX requirements
• Pharmaceutical Company • Regulated by Food and Drug Administration (FDA)
• Clearly Defined Control Policies in Place • Applied to Production and Manufacturing areas • Standard Operating Procedures • Application to Financial systems
• Centralised approach from Corporate • Defined the parameters that were to be used to select the impacted systems • Established a central Project Management Office in the US • Set up a central database which was accessible to impacted parties
• Testing matrices created • Rolled out to sites world-wide • Populated Spreadsheets/Narratives • Agreed with Corporate • Corporate Audit visit in conjunction with external auditors. • Remediation • Reporting to Central Project Office
• Better working relationships with other sites world-wide • Top management support • Timing is very important • Availability of Resources
• Systems identified • Controls in place • Regularly audited
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The Sarbanes-Oxley Act of 2002 was enacted primarily to re-establish ... W., Klamm, B. and Watson Weidenmier, M. (2007), “Surviving Three SOX ...