Need
As a public company with over $2 billion in revenue, an independent power producer needed to comply with the Sarbanes-Oxley Act by the end of the year. Dashe & Thomson had successfully prepared the company for compliance audits in the recent past, and the organization called on us to help them implement Sarbanes-Oxley.

Solution
Dashe & Thomson helped the organization determine what processes they wanted to improve and standardize while undertaking the Sarbanes-Oxley implementation. We performed the following tasks:

• Interviewed process subject matter experts from different regions and power plants to define current processes.
• Facilitated groups to generate improvements to the processes.
• Documented process flows and narratives.

We developed the risks, controls and the ratings for each control to determine the effect and importance of each control on the financial statements.

• Defined the risks and controls in each process.
• Determined the control reliance, impact, likelihood and the financial reporting assertions for each control.

Dashe & Thomson defined the implementation strategy and timeline for implementing and testing the processes at the plants.

• Developed and presented timeline, resources, and costs for testing at the plants.
• Communicated the processes to all the plants, asking for feedback on the difficulty to implement.
• Recommended and developed an online format for the processes on the Intranet so that they could be easily accessed throughout the company.
• Defined the tests for all controls; trained internal testers for initial testing; and conducted initial testing at 20 plants with internal testers, defining gaps and remediation needed.
• Summarized and communicated gaps and remediation.

We developed training for ongoing testing and self-assessment by the company and recommendations for maintenance of the processes.

• Developed and conducted training for Plant Managers so that they could conduct self-testing.
• Trained Internal Auditors on the Operations processes and the test methods.
• Developed recommendations for ongoing maintenance of the processes and role descriptions for Sarbanes-Oxley maintenance.

Result

• The company was able to standardize and improve processes allowing for sharing of best practices.
• Operations Management and Plant Managers are in compliance with Sarbanes-Oxley and are able to continue self-testing and adjustment.