As manager of internal controls and risk management for leading Canadian tissue producer Kruger Products, Mississauga, ON, Jeff Roblin, is responsible for providing compliance and control guidance, remediation plans and reporting for internal controls over financial reporting and 52-109 as well as monitoring SAP system access for segregation of duties violations.
Along the way, Roblin had stops at Pfizer, Wyeth Pharmaceuticals, PwC, and Bennett Gold, working not only in audit of a variety of industries, but in FCPA Compliance, Webtrust, SOX, and asset-based lending.
“The path I’ve taken has allowed me to have a lot of varied experiences, utilize many different methodologies, and apply that to a wide range of scenarios,” he says. As a leader, Roblin likes to offer as much opportunity for people to make their own decisions as possible, relying on discussions and healthy debates over mandates. “I like big brainstorming sessions where we all work to solve the problem,” he says. “I like to give people the framework, a baseline and expectations. I’m very open to doing things different in a smarter way.”
“A significant amount of work had been started before I arrived here, but when I took over, I wasn’t satisfied with the way it had been done.”
Due to a paperwork mistake by Roblin’s high school, his applications were handed in late to universities, so he attended school at Ryerson University which was not his first choice and which wasn’t a very popular business school or known for its accounting program at that time. In fact, when he was graduating in 1997, Ryerson didn’t even have firms come to the school looking for students so Roblin had to look for a job on his own. “I sent out 50 resumes and had 49 rejections,” he says. “The only place I got an interview and subsequently a job was in my home area in Belleville, Ontario, working for Welch & Co. LLC.”
For two years, Roblin planned and executed audit and review engagements, including manufacturing entities, condominiums, charitable organizations and a national chain of hotels. The problem was, even though he was living at home, he was making a meager $23,500 for his full-time job. “At that point in time, I was making less money than a lot of the co-op students were making in Toronto, so in 1999, I made a transition to move to Toronto and went to a $40,000 per year job, and even though I was paying rent, I was more in the money and coming out ahead,” he says. Unfortunately, he and his manager didn’t see eye-to-eye, and six months later, he was out of a job.
At one time, Roblin had been a licensed blackjack dealer, and he listed that on his resume because he didn’t have a ton of job experience and he wanted to make it interesting. He landed a job at Bennett Gold Chartered Accountants because the company had just landed the client, GalaxyWorld.com, an online casino that was gaining in popularity. “The first 2-3 weeks of my employment, I was playing online gambling to ensure the payouts matched the tables and games were operating as they should no matter how you played the games, how you shuffled, and that everything operated correctly,” he says. “If we won money, we took if off the bill and if we lost money, it was a disbursement. I was the only one at the firm ever to make money playing games of chance.”
After another career turn with PricewaterhouseCoopers from 2003-2006, Roblin entered the pharmaceutical biz with a four-year run at Wyeth Pharmaceuticals, and two years at Pfizer Pharmaceuticals. Now he’s at Kruger Products, where he’s responsible for providing compliance and control guidance, remediation plans and reporting for internal controls over financial reporting and 52-109 as well as monitoring SAP system access for segregation of duties violations. “My experience with 52-109 really started at PricewaterhouseCoopers. In 2004, the U.S. was really getting heavy into the implementation of SOX and I was one of the individuals who went to New York City to work because there were not enough CPAs in the U.S. to go around,” he says. “I was there documenting and drafting controls and laying groundwork for certain companies so they could become SOX compliant.”
Kruger Products is currently in its third year of 52-109 compliance, which includes risk assessment, documentation of processes and controls, design effectiveness, and operational effectiveness “A significant amount of work had been started before I arrived here, and when I took over, I wasn’t satisfied with the way it had been done,” he says. “I was trying to harmonize the documentation into something that provided a good overall view of the control environment.” In its first year, Kruger Products had a 25 percent control deficiency rate, but it was a number Roblin was happy about. “It was a livable number, for the first year of operational effectiveness testing and we knew where we had gaps,” he says. “Last year, we brought that down to a 16 percent deficiency rate—a significant improvement.”
Another component of Roblin’s responsibilities is monitoring SAP for segregation of duties violations (SODs), creating mitigating controls as well as reviewing all new access requests during the onboarding process. Since SAP was not previously managed tightly from a risk standpoint, there were a significant amount of access violations. “When I ran the initial SOD report, the rate of SOD violations companywide was pervasive. Now we have managed that risk down by almost 85 percent,” he says. His goal is to eliminate almost all SODs over time. “I am not looking to assign blame and that is not the purpose of the exercise. Prior to becoming a public company, we were primarily focused on operations. SAP was assigned in a manner that every user had all the access that was relevant without impediment,” he says. “As a result, there was a significant amount of access no longer being used, examples of pervasive access and certain roles required a great deal of reconfiguration.”