PepsiCo GRC
PepsiCo GRC
PepsiCo GRC
:
GCS Implementation
A Governance-Risk-Compliance (GRC) Program
Challenge Addressed
Without a formal and central documentation system, the preparation time and, therefore, business
disruption for internal GCS audits and SOX reporting was very high, and inconsistent process
knowledge was a source of insecurity as it pertained to the outcome of the audits. PCMIL also needed to
address an acute lack of easy accessibility to the documentation and process flows for auditors and
employees, as well as inconsistencies and gaps in their process documentation that were compounding
problems associated with manual audit preparation. Although approximately 100 critical processes had
been mapped with Microsoft Visio and role matrices had been documented in MS Excel , processes
were decentralized and managed manually and independently of GRC programs. PCMIL did not
have a system in place to support their GCS implementation initiative, and frequent, manual process
updates, as well as the audit process itself, were proving time-consuming and costly due to a lack of
integration with business processes.
Desired Outcome(s)
In order to address the aforementioned challenges, PCMILs GCS compliance team sought to:
-
Reduce preparation time, costs, and the risk of human error associated with GCS and SOX
audits
Increase process clarity and transparency; improve visibility of risks; pass the GCS audit
Create a Process Library that would include the highest priority aspects of critical process areas
using industry-standard best-practices for process modeling (BPMN)
Centralize processes; facilitate the management of the process lifecycle, including processrelated information such as risks, controls, documents, business rules, roles, and resources
Clarify and document roles and responsibilities to ensure segregation of duties for SOX
compliance
Establish a clear audit trail to facilitate the compliance side of continuous process improvement;
reduce the need for manual process updates and reporting
Generate reports automatically: Control Matrix, GCS Matrix, Audit Trail, SoD Report, RACI
Report
PCMIL selected Interfacings Enterprise Process Center (EPC) as the supporting technology for its
ability to embed global controls in their business processes. An important first step was the delivery of a
Process Library in the form of a centralized EPC repository once PCMILs existing processes had been
validated and migrated into the EPC. Cross-functional processes were mapped with the direct
collaboration of the line-of-business managers involved in Purchase-to-Payable, Inventory-to-Cost, Salesto-Collection, Financial Reporting, and Fixed Assets. Top management at the plant, including Finance,
Quality, Manufacturing and Inventory Control participated fully in the process, thus enhancing the
proportional ownership of this important project. In addition, the local team benefitted from the
participation of a steering team at headquarters providing oversight on a monthly basis
PCMIL process modelers captured and documented process-related information, including documents,
risks, controls, business rules, roles, and resources, that they then linked directly to processes in the
EPC. They utilized the EPCs best-practice RACI (Responsible / Accountable / Consulted / Informed)
framework to define roles and responsibilities and leveraged the EPCs integrated Risk Matrix to quantify
and prioritize risks in terms of impact and likelihood. With their GCS compliance requirements embedded
in their processes, PCMIL used the EPCs automatic reporting capabilities to generate process
documentation and audit reports.
Outcome(s) Achieved
PCMIL met their primary objective by integrating global control and governance strategies at the process
level. Rather than treating the internal audit process as a one-time or periodic project, they have
integrated this GRC initiative as an ongoing part of business operations. The improved approach to GCS
implementation was successful because it was easily adopted by employees at all levels of the
organization; there are approximately 100 non-technical users accessing the system.
Due to the centralized EPC Process Library, roles and responsibilities are clearly defined and
documented, enforcing the segregation of duties for SOX compliance. The EPC has ensured that process
knowledge is visible and consistent across the organization and easily accessible to PCMIL employees
and auditors. This has increased Management and employee confidence around the GCS audit, as those
involved are able to give precise and detailed responses to process and control-related inquiries. Risks
are immediately visible, and controls are linked directly to the appropriate processes, and are being
actively monitored in the EPC. The project team is currently determining the average cost savings
associated with eliminating the need for manual process updates and with automatic report generation as
part of the additional project phases. In the Fall of 2010, PCMIL confidently passed their internal audit and
received positive feedback from their corporate auditors, who commented on the clear audit trail left by
the EPC and on the consistency of process knowledge across the organization.