| SOX Compliance and Technology Options | 52 days? | 1/1/2007 | 3/13/2007 | | |
| SOX Compliance Review Preparation | 4 days? | 1/1/2007 | 1/4/2007 | | |
| Meeting with the external audit firm | 1 day? | 1/1/2007 | 1/1/2007 | | External Auditing Firm |
| Define SOX compliance review roles and responsibilities | 1 day? | 1/2/2007 | 1/2/2007 | 2 | External Auditing Firm,CFO,Internal Audit Director |
| Define SOX compliance review and decision processes | 1 day? | 1/2/2007 | 1/2/2007 | 3SS | External Auditing Firm,CFO,Internal Audit Director |
| Create SOX compliance review project plan | 1 day? | 1/3/2007 | 1/3/2007 | 4 | External Auditing Firm,CFO,Internal Audit Director |
| Conduct kickoff meeting | 1 day? | 1/4/2007 | 1/4/2007 | 5 | External Auditing Firm,CFO,Internal Audit Director |
| SOX Compliance Review Preparation Completed | 0 days | 1/4/2007 | 1/4/2007 | 6 | |
| Initiation and Scope | 5 days? | 1/5/2007 | 1/11/2007 | | |
| Determine the systems and processes that are in scope | 0 days? | 1/5/2007 | 1/5/2007 | 4,6 | Accounting,SOX Compliance Team |
| Build communications plan for project participants and stakeholders | 1 day? | 1/5/2007 | 1/8/2007 | 9 | SOX Compliance Team |
| Identify SOX training requirements for project participants | 1 day? | 1/8/2007 | 1/9/2007 | 10 | SOX Compliance Team |
| Define project plan, key milestones, budget, and key project participants | 1 day? | 1/9/2007 | 1/10/2007 | 11 | SOX Compliance Team |
| Define project progress reporting and structure for senior management | 1 day? | 1/10/2007 | 1/11/2007 | 12 | SOX Compliance Team |
| Project Initiation Complete | 0 days | 1/11/2007 | 1/11/2007 | 13 | |
| Review and Identify Improvement Opportunities | 24 days? | 1/11/2007 | 2/13/2007 | | |
| Perform Risk Assessment | 4 days? | 1/11/2007 | 1/16/2007 | | |
| Review and confirm risk factors | 1 day? | 1/11/2007 | 1/12/2007 | 14 | SOX Compliance Team |
| Validate probability and impact of risk factors | 1 day? | 1/12/2007 | 1/15/2007 | 17 | SOX Compliance Team |
| Estimate and validate size and complexity of risk factors | 1 day? | 1/15/2007 | 1/16/2007 | 18 | SOX Compliance Team |
| Identify Significant Accounts and Internal Controls | 2 days? | 1/16/2007 | 1/17/2007 | | |
| Identify and validate application controls over the initiating, recording, processing, and reporting | 1 day? | 1/16/2007 | 1/17/2007 | 19 | SOX Compliance Team |
| Confirm General IT Controls | 3 days? | 1/17/2007 | 1/19/2007 | | |
| Review Security Policies and Procedures | 1 day? | 1/17/2007 | 1/18/2007 | 21 | IT Network & Infrastructure Team,SOX Compliance Team |
| Review Change Management Policies and Procedures | 2 days? | 1/17/2007 | 1/18/2007 | | |
| Review version management/release management procedures | 1 day? | 1/17/2007 | 1/18/2007 | 23SS | IT Applications Team,IT Network & Infrastructure Team,SOX Compliance Team |
| Review source code/document version control procedures | 1 day? | 1/17/2007 | 1/18/2007 | 23SS | IT Applications Team,IT Network & Infrastructure Team,SOX Compliance Team |
| Review Disaster Recovery Procedures | 1 day? | 1/17/2007 | 1/18/2007 | 23SS | IT Network & Infrastructure Team,SOX Compliance Team |
| Review Backup and Recovery Procedures | 1 day? | 1/17/2007 | 1/18/2007 | 23SS | IT Network & Infrastructure Team,SOX Compliance Team |
| Review Service-Level Agreement Policies | 1 day? | 1/17/2007 | 1/18/2007 | 23SS | IT Director / Manager,IT Applications Team,IT Network & Infrastructure Team,SOX Compliance Team |
| Review Application Development and Coding Standards/Review Procedures | 1 day? | 1/17/2007 | 1/18/2007 | 23SS | IT Applications Team,SOX Compliance Team |
| Review Testing Policies and Procedures | 1 day? | 1/17/2007 | 1/18/2007 | 23SS | IT Applications Team,SOX Compliance Team |
| Review QA procedures | 1 day? | 1/17/2007 | 1/18/2007 | 23SS | IT Applications Team,SOX Compliance Team |
| Summarize Improvement Opportunities Findings | 1 day? | 1/18/2007 | 1/19/2007 | 23,25,26,27,28,29,30,31,32 | SOX Compliance Team |
| Confirm Control Design | 4 days? | 1/19/2007 | 1/24/2007 | | |
| Identify policies and procedures | 1 day? | 1/19/2007 | 1/22/2007 | 33 | Accounting,SOX Compliance Team |
| Review narratives and flowcharts | 1 day? | 1/22/2007 | 1/23/2007 | 35 | Accounting,SOX Compliance Team |
| Review system configuration documentation | 1 day? | 1/22/2007 | 1/23/2007 | 36SS | IT Applications Team,SOX Compliance Team |
| Validate internal control checkpoints and processes | 1 day? | 1/23/2007 | 1/24/2007 | 37 | |
| Evaluate Operational Effectiveness | 4 days? | 1/24/2007 | 1/29/2007 | | |
| Identify/confirm labor-intensive and cost-inefficient internal controls | 1 day? | 1/24/2007 | 1/25/2007 | 38 | CFO,Accounting,IT Director / Manager,SOX Compliance Team,Internal Audit Director |
| Prioritize inefficiencies - ongoing costs/internal control risks/cost and efficiency impacts | 1 day? | 1/25/2007 | 1/26/2007 | 40 | CFO,SOX Compliance Team,Internal Audit Director |
| Develop cost estimates and efforts for prioritized improvement | 1 day? | 1/26/2007 | 1/29/2007 | 41 | CFO,SOX Compliance Team,Internal Audit Director |
| Finalize Cost/Benefit Analyses | 12 days? | 1/29/2007 | 2/13/2007 | | |
| Group improvements opportunities into technology improvement projects | 1 day? | 1/29/2007 | 1/30/2007 | 42 | CFO,Accounting,IT Director / Manager,SOX Compliance Team,Internal Audit Director |
| Develop cost/benefit analyses | 1 day? | 1/30/2007 | 1/31/2007 | 44 | CFO,Accounting,IT Director / Manager,SOX Compliance Team,Internal Audit Director |
| Develop future state scenarios and opportunity savings | 1 day? | 1/31/2007 | 2/1/2007 | 45 | CFO,Accounting,IT Director / Manager,SOX Compliance Team,Internal Audit Director |
| Identify gaps | 1 day? | 2/1/2007 | 2/2/2007 | 46 | CFO,Accounting,IT Director / Manager,SOX Compliance Team,Internal Audit Director |
| Identify project risks and impacts of doing nothing | 5 days? | 2/2/2007 | 2/9/2007 | 47 | SOX Compliance Team |
| Identify additional key resources and information sources | 1 day? | 2/9/2007 | 2/12/2007 | 48 | CFO,Accounting,IT Director / Manager,SOX Compliance Team,Internal Audit Director |
| Validate scope, participants and efforts | 1 day? | 2/12/2007 | 2/13/2007 | 49 | CFO,Accounting,IT Director / Manager,SOX Compliance Team,Internal Audit Director |
| Improvement Design Complete | 0 days | 2/13/2007 | 2/13/2007 | 50 | |
| Control Design | 10 days? | 2/13/2007 | 2/26/2007 | | |
| Project kickoff meeting | 1 day? | 2/13/2007 | 2/14/2007 | 50 | IT Applications Team,SOX Compliance Team |
| Design new systems and cross-reference to related internal controls | 1 day? | 2/14/2007 | 2/15/2007 | 53 | IT Applications Team,SOX Compliance Team |
| Identify technologies that will be implemented | 2 days? | 2/15/2007 | 2/16/2007 | | |
| Identify data capture and editing systems | 1 day? | 2/15/2007 | 2/16/2007 | 54 | IT Applications Team,SOX Compliance Team |
| Identify logging and monitoring systems | 1 day? | 2/15/2007 | 2/16/2007 | 56SS | IT Applications Team,SOX Compliance Team |
| Identify analysis and reporting systems | 1 day? | 2/15/2007 | 2/16/2007 | 56SS | IT Applications Team,SOX Compliance Team |
| Design necessary process changes | 1 day? | 2/16/2007 | 2/19/2007 | 56,57,58 | IT Applications Team,SOX Compliance Team |
| Create policies, standards, and procedures | 1 day? | 2/19/2007 | 2/20/2007 | 59 | IT Applications Team,SOX Compliance Team |
| Communicate changes that will required | 1 day? | 2/20/2007 | 2/21/2007 | 60 | IT Applications Team,SOX Compliance Team |
| Identify appropriate frequency of control | 1 day? | 2/21/2007 | 2/22/2007 | 61 | IT Applications Team,SOX Compliance Team |
| Finalize design | 1 day? | 2/22/2007 | 2/23/2007 | 62 | IT Applications Team,SOX Compliance Team |
| Obtain approvals needed (SOX Compliance/Management) | 1 day? | 2/23/2007 | 2/26/2007 | 63 | IT Applications Team,SOX Compliance Team |
| Control Design Complete | 0 days | 2/26/2007 | 2/26/2007 | 64 | IT Applications Team,SOX Compliance Team |
| Development | 4 days? | 2/26/2007 | 3/1/2007 | | |
| Develop/implement redesigned systems and/or controls | 1 day? | 2/26/2007 | 2/27/2007 | 65 | IT Applications Team,SOX Compliance Team |
| Re-communicate all changes to all impacted groups | 1 day? | 2/27/2007 | 2/28/2007 | 67 | IT Applications Team,SOX Compliance Team |
| Validate internal controls maintained and/or improved | 1 day? | 2/28/2007 | 3/1/2007 | 68 | IT Applications Team,SOX Compliance Team |
| Development complete | 0 days | 3/1/2007 | 3/1/2007 | 69 | |
| Testing | 5 days? | 3/1/2007 | 3/7/2007 | | |
| Validate control effectiveness | 1 day? | 3/1/2007 | 3/2/2007 | 70 | IT Applications Team |
| Document test cases/results in detailed test plans and summaries | 1 day? | 3/2/2007 | 3/5/2007 | 72 | IT Applications Team |
| Validate improvement and/or remediation actions accomplished | 1 day? | 3/5/2007 | 3/6/2007 | 73 | IT Applications Team |
| Document testing results | 1 day? | 3/6/2007 | 3/7/2007 | 74 | IT Applications Team |
| Testing complete | 0 days | 3/7/2007 | 3/7/2007 | 75 | |
| Implement | 5 days? | 3/7/2007 | 3/13/2007 | | |
| Update procedures and control documentation | 1 day? | 3/7/2007 | 3/8/2007 | 76 | Accounting,IT Applications Team,IT Network & Infrastructure Team |
| Implement system changes | 1 day? | 3/8/2007 | 3/9/2007 | 78 | Accounting,IT Applications Team,IT Network & Infrastructure Team |
| Monitor results and improvements | 1 day? | 3/9/2007 | 3/12/2007 | 79 | Accounting,IT Applications Team,IT Network & Infrastructure Team,SOX Compliance Team |
| Document results and summarize to senior management | 1 day? | 3/12/2007 | 3/13/2007 | 80 | Accounting,IT Applications Team,IT Network & Infrastructure Team,SOX Compliance Team |
| Implementation complete | 0 days | 3/13/2007 | 3/13/2007 | 81 | |
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