We spent the first six to eight months of the SOX project figuring out how we were going to do this.

Since we didn’t have a lot of our policies, procedures and standards documented, we needed to come up with a basic framework that we could use to get started.

Once we adopted a framework for developing policies, standards and procedures, we made really good progress. The documentation process really started to fall into place.

We still have a lot more work to do, but as far as the documentation and general infrastructure of our processes, it’s pretty much done.