Sarbanes-Oxley Compliance Assessment

In order to determine the weaknesses in your Sarbanes Oxley / Basel ii effort, a confidential SWOT analysis (Strengths, Weaknesses, Opportunities and Threats Analysis) of  your current compliance situation is necessary. This will give us the knowledge needed to build on the strengths of the previous program, correct weaknesses isolating the areas we need to focus on and protect against vulnerabilities and threats.

The key steps in conducting a SWOT analysis of your current compliance situation include:

1. To create lists of strengths, weaknesses, opportunities and threats.

2. To review each category separately and to analyze the potential implications to the organization.

3. To conduct problem analysis. We will analyze weaknesses and determine the root causes. We never blame people – we only identify appropriate solutions (for example, training).

 Data Collection

Choosing the appropriate structure and adherence to faithful representation of the facts (agreement about anonymity, for example) are critical in obtaining unbiased feedback.

 Data Collection Methods

The following data collection methods will be used in order to collect all the necessary information.

 Method 1: Surveys and Questionnaires

Open-ended questions give the opportunity of valuable feedback. They begin with words such as "why" and "how" or phrases such as "What do you think about. They are valuable because they lead employees to think analytically and critically, giving greater freedom of expression and avoiding bias due to limited response ranges.

Open-ended questions allow respondents to include more information, including feelings, attitudes and understanding of the subject. This allows researchers to better access the respondents' true feelings on an issue.

Closed-ended questions limit respondents' answers. Employees are allowed to choose from either a pre-existing set of answers, such as yes/no, true/false, or multiple choice with an option for "other" to be filled in, or ranking scale response options. They are quick to answer and easy to code.

 Method 2: Interviews and Focus Groups

Interviews and focus groups will be used to gather detailed, qualitative descriptions of how programs operate and how stakeholders perceive them.

Research has shown that individual interviews are the most effective means for getting feedback. They will be conducted one-on-one, while focus groups are conducted in small groups. Both are usually conducted with targeted samples of stakeholders. Interviews can yield valuable insights that may have been overlooked in a formal survey. The questions will be open-ended, which gives participants freedom to answer, and an experienced facilitator will keep people focused on the topic. Questions are generally open-ended and responses are documented in thorough, detailed notes or transcription. However, some interviews will use structured quantitative response categories.

Method 3: Observations

Observations are a generally unobtrusive method for gathering information about how the program or initiative operates. They will be conducted by external evaluators and will be used to verify and supplement information gathered through other methods.

Most observations will be highly structured, with protocols for recording specific behaviors at specific times. Some observations will be unstructured, taking a “look-and-see” approach.

The following types of observation will be used:

A. Participant Observation

It is one of the most important methods for qualitative data collection. The researchers become participants in the culture or context being observed. 

B. Direct Observation

Direct observers will not try to become participants in the context.  However, they will strive to be as unobtrusive as possible so as not to bias the observations.  The researchers will be watching rather than taking part. Direct observation tends to be more focused than participant observation 

C. Unstructured Interviewing

Unstructured interviewing involves direct interaction between the researcher and a respondent or group.  It differs from traditional structured interviewing in several important ways: There is no formal structured instrument or protocol.  The interviewer is free to move the conversation in any direction of interest that may come up. 

Method 4: Tests and Assessments

Tests and assessments will be developed and used specifically for the program evaluation to quantify characteristics of the program and outcomes. It is a simple, reliable, and valid way to measure whether a program has impact. Using the same data collection method to gather information before the start of the program and after its completion (also known as a pre/post tests, containing gap-filling, construction in context and error recognition questions) provides the opportunity to determine whether some characteristic changed during the course of the program.

 Method 5: Document Reviews

 Document reviews will analyze existing program records and other documents not gathered or developed specifically for the evaluation.

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