Separation of concerns
Segregation of duties
Six duty pairs that should not sit in one pair of hands. more
Health
Whether incompatible duties are separated
Segregation rules in force, the conflicts detected against them and how many have been mitigated.
This is the finding, not a decoration. 291 of 385 conflicts have no named owner and no remediation date. Detection is working; triage is not keeping up with it. That gap is carried as an open exception on CTL-005.
The duty pairs
What each rule separates, how it is enforced, and how many holders it currently finds.
SOD-01Raise and approve the same item
Raise a request or a work itemagainstApprove, escalate or clear that same item
CriticalBlocking
The oldest control in existence. more
When it is breached: The decision interface refuses the action, names the rule, and writes a refusal record to the evidence spine under the requester identity.
8
detected live
8
on the books
0
unowned
4
mitigated
SOD-02Own a station and clear its own gate
Own the station that produces the workagainstApprove the gate that checks that station
HighDetective
A gate approved by the person who owns the work upstream of it is a formality. more
When it is breached: Detected and listed. Not blocked, because in many small functions there is genuinely nobody else — the compensating control is that the conflict is named and owned.
153
detected live
153
on the books
122
unowned
13
mitigated
SOD-03Approve a policy and clear the gate it governs
Approve the policy itemagainstApprove a gate on a line the policy binds
HighDetective
Writing the rule and then judging compliance with it collapses two independent checks into one opinion.
When it is breached: Detected and listed with the policy reference and the gate that is affected.
153
detected live
153
on the books
120
unowned
9
mitigated
SOD-04Own an agent and attest its own rating
Own the sub-function whose agents are being changedagainstStand behind the estate rating that grades those agents
HighDetective
A rating signed by the person whose numbers it grades is a self-assessment. more
When it is breached: Detected and listed. Independent re-rating is the remediation, not removal of the owner.
69
detected live
69
on the books
49
unowned
8
mitigated
SOD-05Delegate authority to oneself
Act as the delegator on an authority grantagainstHold the grant that was delegated
CriticalDetective
Self-delegation makes the authority register circular. more
When it is breached: Detected and listed. A self-delegated grant should be revoked and re-issued by the level above.
0
detected live
0
on the books
0
unowned
0
mitigated
No holder of this pair anywhere in the estate. Reported as zero because it is zero, not because the rule is switched off.
SOD-06Own a control and perform its own test
Own the controlagainstPerform the test that decides whether the control works
MediumDetective
This is the difference between "we have gates" and "the gates were tested by someone who does not run them".
When it is breached: Detected and listed. The test result is retained but is marked as not independent.
2
detected live
2
on the books
0
unowned
0
mitigated
Who holds both sides most often
Concentration matters more than the raw count. more
VP Revenue Growth Management5
Director, Legal Operations5
Director, Demand Development3
Director, Sales Enablement3
Director, Sales Compensation3
Director, Market Intelligence3
VP Demand Generation3
Director, Content3
Conflict register
27 matching, showing up to 120
Filtered to administration · clear
| Reference | Holder | Where | Both sides | Owner and fix | State |
|---|---|---|---|---|---|
| SOD-02-58BA5371SOD-02 | Director, Workplace ServicesStation owner and gate approver | AdministrationFacilities & Workplace | A. Owns 2 stations on line AD1C B. Approves the same 2 gates: Approve, Ratify | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-09-04 | Mitigated |
| SOD-02-BFC2D538SOD-02 | VP Corporate Real EstateStation owner and gate approver | AdministrationReal Estate Portfolio | A. Owns 3 stations on line AD2C B. Approves the same 3 gates: Ratify, Approve, Ratify | No owner assigned | Detected, unowned |
| SOD-02-321E994ASOD-02 | Director, Travel & ExpenseStation owner and gate approver | AdministrationTravel & Expense | A. Owns 3 stations on line AD3A B. Approves the same 3 gates: Approve, Exception review, Ratify | No owner assigned | Detected, unowned |
| SOD-02-2C1B6052SOD-02 | Chief of Staff, CorporateStation owner and gate approver | AdministrationExecutive Support | A. Owns 1 station on line AD4B B. Approves the same 1 gate: Approve | No owner assigned | Detected, unowned |
| SOD-02-A6DD849BSOD-02 | Director, Corporate EventsStation owner and gate approver | AdministrationMeetings & Events | A. Owns 2 stations on line AD5A B. Approves the same 2 gates: Budget approve, Ratify | No owner assigned | Detected, unowned |
| SOD-02-DB0B93ABSOD-02 | Chief Records OfficerStation owner and gate approver | AdministrationRecords & Information Management | A. Owns 5 stations on line AD6A B. Approves the same 5 gates: Disposition approve, Hold check, Ratify and others | No owner assigned | Detected, unowned |
| SOD-02-4497B6F8SOD-02 | Director, Fleet & AssetsStation owner and gate approver | AdministrationFleet & Assets | A. Owns 2 stations on line AD7C B. Approves the same 2 gates: Approve, Approve | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. moredue 2026-09-10 | In remediation |
| SOD-02-CE7065E5SOD-02 | Head of EHSStation owner and gate approver | AdministrationEnvironment Health & Safety | A. Owns 3 stations on line AD8C B. Approves the same 3 gates: Ratify, Corrective action, Regulatory file | No owner assigned | Detected, unowned |
| SOD-02-43941F20SOD-02 | Director, Business ContinuityStation owner and gate approver | AdministrationBusiness Continuity | A. Owns 5 stations on line AD9B B. Approves the same 5 gates: Remediation plan, Stand down, Activate and others | No owner assigned | Detected, unowned |
| SOD-02-9EB33B0ASOD-02 | Director, Corporate ServicesStation owner and gate approver | AdministrationCorporate Services | A. Owns 2 stations on line AD10C B. Approves the same 2 gates: Ratify, Review | No owner assigned | Detected, unowned |
| SOD-02-269C0316SOD-02 | Manager, Hospitality ServicesStation owner and gate approver | AdministrationHospitality & Reception | A. Owns 1 station on line AD11A B. Approves the same 1 gate: Credential | No owner assigned | Detected, unowned |
| SOD-03-DB9EBDA6SOD-03 | Director, Workplace ServicesPolicy approver and gate approver | AdministrationFacilities & Workplace | A. Approved 2 policy items: AD1-POL-200, AD1-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-57A08939SOD-03 | VP Corporate Real EstatePolicy approver and gate approver | AdministrationReal Estate Portfolio | A. Approved 2 policy items: AD2-POL-201, AD2-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-DF82A49DSOD-03 | Director, Travel & ExpensePolicy approver and gate approver | AdministrationTravel & Expense | A. Approved 3 policy items: AD3-POL-202, AD3-POL-200, AD3-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-A896CAE5SOD-03 | Chief of Staff, CorporatePolicy approver and gate approver | AdministrationExecutive Support | A. Approved 2 policy items: AD4-POL-201, AD4-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-5F2714D2SOD-03 | Director, Corporate EventsPolicy approver and gate approver | AdministrationMeetings & Events | A. Approved 3 policy items: AD5-POL-200, AD5-POL-201, AD5-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-73525786SOD-03 | Chief Records OfficerPolicy approver and gate approver | AdministrationRecords & Information Management | A. Approved 4 policy items: AD6-POL-200, AD6-POL-201, AD6-POL-202, AD6-POL-203 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-5E62F527SOD-03 | Director, Fleet & AssetsPolicy approver and gate approver | AdministrationFleet & Assets | A. Approved 2 policy items: AD7-POL-200, AD7-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-F7CCFB5ESOD-03 | Head of EHSPolicy approver and gate approver | AdministrationEnvironment Health & Safety | A. Approved 4 policy items: AD8-POL-203, AD8-POL-202, AD8-POL-201, AD8-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-533B6DFFSOD-03 | Director, Business ContinuityPolicy approver and gate approver | AdministrationBusiness Continuity | A. Approved 3 policy items: AD9-POL-201, AD9-POL-202, AD9-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-3C8B7489SOD-03 | Director, Corporate ServicesPolicy approver and gate approver | AdministrationCorporate Services | A. Approved 2 policy items: AD10-POL-200, AD10-POL-201 B. Also approves gates on the lines those policies bind | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. moredue 2026-09-06 | In remediation |
| SOD-03-C9BBE119SOD-03 | Manager, Hospitality ServicesPolicy approver and gate approver | AdministrationHospitality & Reception | A. Approved 4 policy items: AD11-POL-202, AD11-POL-203, AD11-POL-200, AD11-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-04-90DAA907SOD-04 | Director, Workplace ServicesSub-function owner and rating attester | AdministrationFacilities & Workplace | A. Owns 11 agents running at autonomy level 73 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-ECC07752SOD-04 | Director, Travel & ExpenseSub-function owner and rating attester | AdministrationTravel & Expense | A. Owns 11 agents running at autonomy level 77 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-03EC3239SOD-04 | Director, Fleet & AssetsSub-function owner and rating attester | AdministrationFleet & Assets | A. Owns 9 agents running at autonomy level 78 B. Stands behind the A estate rating that grades those same agents | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. moredue 2026-09-02 | Mitigated |
| SOD-04-728F1B69SOD-04 | Director, Corporate ServicesSub-function owner and rating attester | AdministrationCorporate Services | A. Owns 10 agents running at autonomy level 76 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-7184A79BSOD-04 | Manager, Hospitality ServicesSub-function owner and rating attester | AdministrationHospitality & Reception | A. Owns 9 agents running at autonomy level 83 B. Stands behind the A estate rating that grades those same agents | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-09-04 | In remediation |
Actions
What is waiting on a person
A separation rule is only real when somebody unwinds the combinations it forbids. more
291
Start unwinding a detected conflict
Found by the rule and nobody has picked it up.
60
Finish a remediation already underway
Owner named, plan written, not yet closed.
60
Escalate a conflict past its date
Past the remediation date on the record and still combining both duties.
5
Decide whether a detective rule should block
These rules report a conflict after the fact instead of preventing it.
Operations
What this desk is allowed to start
A surface that only reports is not operable. more
Trigger and bound
This desk can raise, reassign or mitigate a conflict, and it can change a rule between detective and blocking. more
Live observability
What the record shows right now
Conflict states across the estate. more
Current distribution
385 conflicts
Detected, untouched29176%
In remediation6016%
Mitigated349%
Is policy and strategy coming to fruition
Whether the written intent is holding here
351 live conflicts against 6 written rules, and 5 of those rules cannot stop anything.
Not holding on the record
The written position is that no single holder should be able to both initiate and approve the same class of commitment. more
How to read this honestly
One rule is blocking and five are detective. SOD-01 is refused at the decision interface — the person who raised a work item cannot approve it, the attempt fails with the rule named, and a refusal record is written to the evidence spine. The other five are found and listed but not prevented, because in a sub-function with one senior person there is genuinely nobody else to hold the second duty. Naming the conflict and giving it an owner is the compensating control, and 291 of them do not have one yet.
The live detector and the standing register are computed by the same code, so they cannot drift apart. 4 conflicts are visible to the detector but have never been triaged onto the register. 4 rows on the register are no longer found in the estate and can be closed.