The objective of this procedure is to describe purpose and process related to the BFC internal controls (users accesses management, customizing activities, sensitive actions from BFC Administration team…).
Both maintenance and customizing activities must be performed in compliance with internal controls designed with Data Compliance and Audit team and audited twice a year by Solvay external auditors (mid-year and year-end cycles).
Main risks to be covered are the following:
BFC Administration team is the control owner of the following internal controls: Audit
Purpose: Check the compliance of BFC users passwords with Solvay Security policy
This Control is restricted to “Internal Users” (authentication type "internal") as “External Users” (authentication type "external") are using the Single Sign On.
Description: The BFC Administration team reconciles an extract of password settings from the BFC_Production system and the password guidelines included in the security policy: all the directives must be respected.
Control type: (Completeness, Accuracy, Validation, and Restricted Access): Completeness, Accuracy and Restricted Access
Frequency: from May 2022,"on flow" when Solvay’s password policy changes (before frequency was a yearly one)
Note: use of special characters (such as @ #) can not be forced as it prevents users to use retrieves of BFC figures in Excel
Control evidence:
In “Action” menu / “Password Manager” option, the BFC Administration team defines length of Internal password as well as their validity duration.
From May 2022 parameters adapted:


Evidence stored in GDrive: https://drive.google.com/drive/folders/1GI_ZB6EsHhhHrVKSolXdjofT3ip0LFNI

Purpose: All the Functional Profiles creation/modification requests are formally validated by the GAR Consolidation Manager (appointed as KUF = Key User Function).
Description: The BFC Administration team, before updating the role into the system, checks manually the presence of incompatibilities in the role design, according to the matrix of incompatible actions. In case of some incompatibilities are found he/she informs the Consolidation Manager (KUF) who validates them.
A functional profile defines the types of rights to perform specific tasks in the application. For example, whether or not a user is authorized to create, change or delete data in schedules.
The major risk to be managed is to avoid to introduce in Functional profiles (through creation / modification) incompatible rights without any authorization from KUF.
Control type: (Completeness, Accuracy, Validation, and Restricted Access): Validation, Accuracy
Frequency: On Flow, ie everytime there’s a need to change or create a functional profile
A) Functional Profiles created in BFC since its implementation in 2005

B) Functional Profiles currently used (31/05/2022)

C) Description of Functional Profiles currently used (31/05/2022)

Evidence stored in GDrive: https://drive.google.com/drive/folders/19Dc-vvsciksgLYn2UK4uYbuZbLyxGdw2

Purpose: Matrix of incompatible transactions by critical level is maintained and updated in order to include each new critical transaction.
Description: The file “IT FC SEC-04 Access Rights 2022” is a validation of the updated matrix of incompatibilities by the Key User Function (Consolidation manager):
- Functional profile ADMINISTRATION: "full power" users authorized to modify (creation and deletion) all of the objects and data in SAP Financial Consolidation.
- Functional profile RTR BO-COR: the combination of rights to 1) unlock packages + 2) modify data inside + 3) publish packages modified should be considered conflicting duties.
The "Functional Profiles Definitions" tab is a detailed description of the Functional Profiles.
Control type (Completeness, Accuracy, Validation, and Restricted Access): Validation
Evidence stored in GDrive: https://drive.google.com/drive/folders/1cZ5Dm7QTzifrxoy6yjRXabrdURMwPlo2

Frequency: From May 2022, "On Flow", each time we change or create a functional profile (consistent with SEC-03)
Purpose: Access rights given to users are formally validated by the BFC Administration team.
Description: Access requests are sent by e-mail or via Service One ticket (transferred by IS BFC Admin) to the BFC-Admin mailbox, normally the request is performed by the user with his/her manager in copy (manager as defined in Solvay One Organizational chart).
Important Notes:

Control type: (Completeness, Accuracy, Validation, and Restricted Access): Validation and Restricted Access
Frequency: On demand @ each user access request
Evidence stored in GDrive: https://drive.google.com/drive/folders/1eGfCz_979YQ-M4EW3KDpFNCXKugxZuls

Purpose: Users list with sensitive accesses is reviewed by Consolidation manager (KUF) before each quarterly closing
Description:
Control type: (Completeness, Accuracy, Validation, and Restricted Access): Validation and Restricted Access
Frequency: Quarterly in March - June - September - December, before quarterly closing process
Validation process:
Evidence stored in GDrive: https://drive.google.com/drive/folders/14oLPoNU-cUuCIE6a0fxK5XPsgr1JHQPD
ADDITIONAL QUARTERLY PROCESS - INSIDER'S DEALING (FSMA)
Purpose 1: Deactivation done on a regular basis for leavers and movers.
Description: The Solvay Group members who have access to BFC should be compliant with their status and their position on HR tools. The objective of this Internal Control is to reconcile the users status on BFC according to their HR status and identify the users that should be deactivated from BFC.
Deactivation is done based on the lists provided by IT Internal Control team (Risk and Compliance):
Leavers process (Internals & Externals) - weekly
Email sent from IT Internal Controls team:

BFC Admin should make a copy of the file sent in the email to BFC internal controls GDrive folder (or download it to excel and upload it in the GDrive afterwards).

In the new file (just copied from the file received), the following changes have to be made:

In tab BFC deactivation copy/paste the print screen from BFC showing that users have been blocked.

Movers - monthly
Email sent from IT Internal Controls team:

BFC Admin should make a copy of the file sent in the email to BFC internal controls GDrive folder (or download it to excel and upload it in the GDrive afterwards).
Unlike in leavers file, in the movers file we receive all leavers since Jan.1st until Dec.31st.
Therefore, as some users have been already treated by BFC Admin in previous months, we need to start by filtering the file by the new movers.
Filtering by Calendar Day and selecting the new dates not present in previous month file will give the new movers:

Each case must be analyzed in a different tab as different comments need to be provided.

The users in the file have had a change either in Business Unit, or Job Function or Job Classification.
Below are the examples of the emails sent to users (and their managers in cc) who have changed
1) Business Unit

2) Job Function

3) Job classification

Not all the cases may require an email sending from BFC Admin because the access rights may have already been updated.
And not all the cases may require an access update despite the change in job function or job classification.
Examples of the situations that may occur:
1) The access rights are already according to new position - Sometimes the user or his/her manager have already requested the access rights update

2) Access rights should be kept - It has to be the user (with manager in CC) or the manager to inform it

3) Access rights need to be adapted - It has to be the user (with manager in CC) or the manager to inform it

4) Access rights should be cancelled - It has to be the user (with manager in CC) or the manager to inform it

In BFC “Security/Users” module, deactivation will be proceeded the following in the user profile:

and the user must be blocked in order to be prevented from accessing BFC.

Control type: (Completeness, Accuracy, Validation, and Restricted Access): Validation and Restricted Access
Frequency: Weekly (leavers) / Monthly (movers)
Purpose: Temporarily deactivation on BFC when the user has not connected during the last 6 months
Dear Colleague,
Please note that your account for accessing the BFC application has been inactive for more than 6 months. If you have lost the access link, you may connect to BFC by copying and opening this URL https://financialconsolidation.solvay.com/FCPROD/
To avoid disruption of your account, kindly login to BFC within the next 7 days to retain your account. Account will be suspended without further notice thereafter. If your account is being suspended, you may re-submit your access request to $SBS FinanceSL Fin Acc SU BFC Admin
*Please ignore this message if you have connected to BFC before receiving it
Exceptions
“TINSTALL user”:
The user TINSTALL must remain always active:
“ADMIN user”:
The user ADMIN must remain always active:
Evidence stored in GDrive: https://drive.google.com/drive/folders/1DEdG-9J_pkeEQPJtxv4jFv_lklcX49Kk

Purpose: Audit trails on critical activities (deletion of objects) on a regular basis to ensure that all the actions made are justified.
Description: This control traces the sensitives actions in the PRODUCTION environment performed by:
From May 2022: As several controls are already in place to control users accesses (SEC07 Access requests / SEC 09 Review of sensitive accesses / SEC 11 and 12 Users deactivation) and already covering the control of sensitive actions (unlocking, publication by special permission...), critical actions to be monitored through SEC 10 Audit trails are restricted to the deletion of objects.
Note that IT/TEST/TINSTALL profiles don’t have a significant impact in terms of modifications in BFC:
Control Report Process
1) On WD1 of each month, BFC Admin asks DT BFC Admin to extract the audit trail file from Log module;
Below is the email template to be send to DT colleagues:

2) This list contains all deletion actions performed (who and when);
Evidence stored in GDrive: https://drive.google.com/drive/folders/18WARFfNuvQhiqYi3RE8qAxi903Ey8QY4


3) BFC Admin creates tab BFC Admin review (copy from Actions by User profile tab)

Arrange the layout as below in order to be more legible:

4) Finally it should be analyzed for possible anomalies – BFC Administration team Comments - and the file should be sent/shared for BFC Admin manager review;


Control type: (Completeness, Accuracy, Validation, and Restricted Access): Completeness, Accuracy and Validation
Frequency: From May 2022 monthly and focused on deletion of objects (before quarterly frequency was not appropriate as too late to react in case of risky actions taken)
Purpose:
The BFC Administration team is responsible to manage the maintenance of BFC.
The following risks will be covered by the Internal Control framework:
Types of modifications:
The maintenance categories can be grouped in 4 types :
"Recurring maintenances" – Customizing (creation of new objects) with no impact in the data already in the Production environment:
“Critical / sensitive maintenances ” – Customizing (modification of existing objects) with impact in the data already in the Production environment:
A BFC project can be defined as:
List of Authorized requestors (BFC Key Users):
Operating mode for each maintenance category of the BFC Administration team
[A] Reporting set-up Monthly / Quarterly / Yearly
[B] Correction of errors / [C] Improvements (with no impact in the Reporting Content)
[D] Structure Update and Customizing
Internal Controls :
In order to simplify the process, several types of tasks have been created in BFC according to the related process and to the requester:
The BFC Administration team uses always these tasks and their content is transferred to Production. Any piloting from BFC Customizing database (FC_TOP) to BFC production database (FC_PROD) is logged/archived and can be extracted.
Specific Internal controls for tasks type EXPL-CONSO / EXPL-CTRLFIN / EXPL-GESTION / EXPL-TAXES (note: does not apply to EXPL-ADMIN tasks):

Internal Control applicable to ALL tasks type (EXPL-ADMIN / EXPL-CONSO / EXPL-CTRLFIN / EXPL-GESTION / EXPL-TAXES):
Every month , BFC Admin team will:

Assessment of completeness and accuracy of customizing changes:
Every change (creation / update) in BFC customizing is driven by Corporate Consolidation and Controlling needs to perform monthly / quarterly / year end Consolidation and Reporting cycles.
As explained above, piloting of changes to BFC Production can be done using different types of tasks:
At each Consolidation & Reporting cycle, completeness and accuracy of customizing changes can be considered as achieved once the Consolidation and Reporting process of the period is finalized: meaning that consolidation work is finalized as well as analytical reviews and checks from the different stakeholders (Corporate, Accounting, Businesses) before disclosure.
It means as well as that every change on BFC customizing piloted before the beginning of the process has contributed to reach the Consolidation and Reporting needs without any deficiency.
This final - either monthly or quarterly or year end -"Consolidation End state" milestone is formalized by e-mail sent from BFC Admin team to Corporate GAR team requesting the green light to make a back up with locking of the last run IFRS Consolidation (special variant BKUP used) in BFC. Evidences of Corporate GAR's green light to proceed back up and locking posted in this folder GAR Green light for conso back ups

END OF THIS PROCEDURE