Sarbox ABCs for the Rank and File

At Maxtor, the work of the internal controls staff provides the added benefit of buttressing employee training. During "walk-throughs" at various company departments aimed at helping to prepare senior management's controls assessments, staff members talk with employees and managers about documentation of their work. Marks adds that the walk-throughs inadvertently provided another advantage: the company learned that some employees in different offices were unknowingly duplicating work.

"Completing all the work required to document, assess, and test the key controls that together comprise the system of internal control over financial reporting is a challenge, but we have got to make it into an opportunity," said Marks.

Training can also help move compliance from one-off project status to that of an ongoing program that becomes part of the culture, observes Deloitte Consulting's Lee Dittmar, leader of the enterprise governance practice and co-leader of the firm's Sarbanes-Oxley service. To do that, though, managers often must try to change a culture in which employees merely follow orders to one in which they question how senior executives are portraying company performance, he said.

Persistent employee training, in short, is the only way to drive the importance of compliance throughout an organization, according to Dittmar. "It's not one Webinar or training course," he adds. "This is a permanent addition to the ongoing education and training curriculum in the modern organization."

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