A "Well Done" on the status assessment Homework regarding impending SOX 404. Trevor will develop solutions as fast as knowledge about the issue domain is acquired. Note his initial system fix for future reference. You will note also that everything in governance revolves around regulation by rules of action and compliance - blind obedience to authority. The same folks that brought you Viet Nam, simultaneously support a fundamentally opposite scheme -The Malcolm Baldrige National Quality Award.
Your homework is to assimilate the "Criteria for Performance Excellence" available from baldrige.nist.gov. Here you will find the focus on method/process/approach to the exclusion of rules. To get the award, you have to show evidence that your key processes have the fact-based learning feedback loop from results. The criteria book contains a coherent language for appropriate selection of method as central. Yes, the language is tedious.
TQM has failed for the same reason ethics-based Governance has failed. Both regulatory systems try to trick management into adopting a culture that would erode its power. No chance.
The whole issue boils down as to where and how is unavoidable complexity organizationally handled. Hierarchy acts as a vertical conveyor: complexity cascades level through level up to the top and "orders" appropriate to each level cascade down from the "converter." I humanized this complexity-to-workorders transformer as "Grottoman" in my first book. The Greek generals went to Delphi with their war-waging conundrums to a divine converter, we now know to have been some jive broad spaced out and ranting on gaseous polyethylene. In today's corporation the CEO acts as the oracle, being paid to convert (by professional judgment) in direct proportion to the quantity of complexity conveyed upwards to the head shed.
Ponder what it means to the CEOracle to have to show evidence and data logically connected to his assertions in such manner as will be found by an independent auditor that his conclusions are fact-driven. Where does CEO perfect ethics and whim supremacy come in? His extinction is, exactly, what the Baldrige scheme structures.
Ponder what it means to the role of management to have a goal-seeking process, learning and improving as it goes. The only time a learning methodology is effective is when lessons learned is processed immediately by the workface crew. Move that feedback cycle away from the workface and, as Starkermann quantifies in his book, the goal-seeking desire of the workface crew must be reduced to zero - otherwise the social system destabilizes. This is ridiculously easy to demonstrate. Just leave Trevor out of the ends-to-means feedback loop.
I am busy adapting the Baldrige format as a platform for SOX 404 shaping my comments recently solicited by the SEC about "ethics" and "governance" and made available to the public on the SEC website. Whatever flak I get from one bureaucracy I will publicly submit to the other for resolution. It is impossible to win the Baldrige award and have any problem with SEC 404 compliance. Conversely, it is impossible to meet 404 and not qualify for the Baldrige award. It's all about transparency - and that excludes the hierarchy and its ethics. Transparency is all about scrutable connectivity to natural law. Ashby.
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