Opportunity Brief

Executive summary

Halden Group's proposed US listing will bring the organisation into scope of Sarbanes-Oxley Section 404 within 18 months. Today, 71% of its 412 key controls are manual and tested by sample. Aureliant proposes a three-phase programme to establish an evidence-linked control environment, test full populations continuously, and arrive at the first 404(b) attestation with no material weaknesses.

Halden operates across 14 countries on two ERP instances. Internal Audit has identified segregation-of-duties conflicts and period-end manual journal risks that would likely be reported as significant deficiencies under PCAOB AS 2201.

Objectives

1. 01Achieve an unqualified SOX 404(b) opinion in the first attestation year
2. 02Reduce control testing effort by at least 35% through automation and full-population testing
3. 03Give the Audit Committee a single, evidence-linked view of control health
4. 04Embed human review and sign-off for every AI-supported conclusion

Value drivers

Testing effort reduction

38%

Benchmark across 12 comparable programmes

Time to audit-ready

-12 days

Modelled on FY25 close timetable

Population coverage

100%

Automated testing of system-based controls

Deficiency likelihood

-27%

Scenario SCN-SOX-AUTO

Platform modules in scope

• AI SOX Engine
• Audit Readiness Automation
• Executive Intelligence Centre
• Trust & Governance Centre

Phased delivery

1. Phase 16 weeks

   Diagnose

   • Risk & control matrix rationalisation
   • SOD conflict analysis
   • Evidence baseline
2. Phase 212 weeks

   Design & Automate

   • Convert 164 controls to automated
   • Configure continuous testing
   • Owner sign-off workflows
3. Phase 3Ongoing

   Operate & Attest

   • Quarterly control certification
   • Audit Committee reporting
   • External auditor reliance strategy

Risks & mitigations

Governance commitments

• Every AI-supported conclusion routed to a named control owner for approval
• Explainability record retained for each finding
• Immutable audit trail available to Internal Audit and the external auditor
• Model versions governed through the Aureliant Model Registry

Investment & next steps