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
31 matching, showing up to 120
Filtered to ai-gbs · clear
| Reference | Holder | Where | Both sides | Owner and fix | State |
|---|---|---|---|---|---|
| SOD-01-793E2589SOD-01 | GBS CoSItem owner and raiser | AI GBS & Global Business ServicesRework loop analysis — supplier onboarding | A. Raised GBS-1185 — Rework loop analysis — supplier onboarding B. Holds the decision on GBS-1185 in the same queue | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. moredue 2026-09-02 | In remediation |
| SOD-02-DA47319DSOD-02 | Tower Lead, Hire-to-RetireStation owner and gate approver | AI GBS & Global Business ServicesH2R Control Tower | A. Owns 3 stations on line GB1A B. Approves the same 3 gates: Approve, Anomaly review, Exception review | No owner assigned | Detected, unowned |
| SOD-02-4AED7B9CSOD-02 | Tower Lead, Source-to-PayStation owner and gate approver | AI GBS & Global Business ServicesS2P Control Tower | A. Owns 4 stations on line GB2C B. Approves the same 4 gates: Bank verify, Approve, Approve and others | No owner assigned | Detected, unowned |
| SOD-02-63C97BDFSOD-02 | Tower Lead, Order-to-CashStation owner and gate approver | AI GBS & Global Business ServicesO2C Control Tower | A. Owns 3 stations on line GB3D B. Approves the same 3 gates: Credit approve, Hold review, Escalate | No owner assigned | Detected, unowned |
| SOD-02-B232D39DSOD-02 | Tower Lead, Record-to-ReportStation owner and gate approver | AI GBS & Global Business ServicesR2R Control Tower | A. Owns 4 stations on line GB4B B. Approves the same 4 gates: Certify, Review, Sign off and others | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-09-28 | In remediation |
| SOD-02-3EF372E3SOD-02 | Head of Service CatalogStation owner and gate approver | AI GBS & Global Business ServicesService Catalog & Intake | A. Owns 2 stations on line GB5C B. Approves the same 2 gates: Route or refuse, Approve | Head of Agent OperationsAccepted for now with a named risk owner and a review date, because no second qualified approver exists in this sub-function.due 2026-09-29 | Mitigated |
| SOD-02-290B6E0ESOD-02 | Global Process OwnerStation owner and gate approver | AI GBS & Global Business ServicesGlobal Process Ownership | A. Owns 3 stations on line GB6A B. Approves the same 3 gates: Ratify, Ratify, Approve | No owner assigned | Detected, unowned |
| SOD-02-C44CC73ESOD-02 | Head of AutomationStation owner and gate approver | AI GBS & Global Business ServicesAutomation Factory | A. Owns 4 stations on line GB7A B. Approves the same 4 gates: Approve, Control review, Ratify and others | No owner assigned | Detected, unowned |
| SOD-02-AFBAA934SOD-02 | Head of Master DataStation owner and gate approver | AI GBS & Global Business ServicesMaster Data Management | A. Owns 2 stations on line GB8A B. Approves the same 2 gates: Steward review, Approve | No owner assigned | Detected, unowned |
| SOD-02-5A1FCBCESOD-02 | Head of Service DeliveryStation owner and gate approver | AI GBS & Global Business ServicesService Delivery Management | A. Owns 4 stations on line GB9D B. Approves the same 4 gates: Ratify, Ratify, Review and others | No owner assigned | Detected, unowned |
| SOD-02-47866DACSOD-02 | Head of Continuous ImprovementStation owner and gate approver | AI GBS & Global Business ServicesContinuous Improvement | A. Owns 2 stations on line GB10A B. Approves the same 2 gates: Approve, Ratify | No owner assigned | Detected, unowned |
| SOD-02-260569FDSOD-02 | Head of Service EconomicsStation owner and gate approver | AI GBS & Global Business ServicesCost-to-Serve Management | A. Owns 2 stations on line GB11C B. Approves the same 2 gates: Ratify, Review | No owner assigned | Detected, unowned |
| SOD-03-643693DCSOD-03 | Tower Lead, Hire-to-RetirePolicy approver and gate approver | AI GBS & Global Business ServicesH2R Control Tower | A. Approved 2 policy items: GB1-POL-200, GB1-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 2026-09-18 | In remediation |
| SOD-03-8C52B04BSOD-03 | Tower Lead, Source-to-PayPolicy approver and gate approver | AI GBS & Global Business ServicesS2P Control Tower | A. Approved 4 policy items: GB2-POL-203, GB2-POL-200, GB2-POL-201, GB2-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-8DEAE9C4SOD-03 | Tower Lead, Order-to-CashPolicy approver and gate approver | AI GBS & Global Business ServicesO2C Control Tower | A. Approved 4 policy items: GB3-POL-201, GB3-POL-200, GB3-POL-202, GB3-POL-203 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-FC836F8CSOD-03 | Tower Lead, Record-to-ReportPolicy approver and gate approver | AI GBS & Global Business ServicesR2R Control Tower | A. Approved 4 policy items: GB4-POL-201, GB4-POL-203, GB4-POL-202, GB4-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-01D3568ASOD-03 | Head of Service CatalogPolicy approver and gate approver | AI GBS & Global Business ServicesService Catalog & Intake | A. Approved 3 policy items: GB5-POL-200, GB5-POL-201, GB5-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-E263DBF5SOD-03 | Global Process OwnerPolicy approver and gate approver | AI GBS & Global Business ServicesGlobal Process Ownership | A. Approved 2 policy items: GB6-POL-201, GB6-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-DCAE3C6DSOD-03 | Head of AutomationPolicy approver and gate approver | AI GBS & Global Business ServicesAutomation Factory | A. Approved 2 policy items: GB7-POL-200, GB7-POL-201 B. Also approves gates on the lines those policies bind | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-09-24 | In remediation |
| SOD-03-7F784671SOD-03 | Head of Master DataPolicy approver and gate approver | AI GBS & Global Business ServicesMaster Data Management | A. Approved 2 policy items: GB8-POL-201, GB8-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-4E9788E3SOD-03 | Head of Service DeliveryPolicy approver and gate approver | AI GBS & Global Business ServicesService Delivery Management | A. Approved 3 policy items: GB9-POL-202, GB9-POL-200, GB9-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 2026-09-26 | In remediation |
| SOD-03-624D0363SOD-03 | Head of Continuous ImprovementPolicy approver and gate approver | AI GBS & Global Business ServicesContinuous Improvement | A. Approved 4 policy items: GB10-POL-203, GB10-POL-202, GB10-POL-201, GB10-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-E2D2A2ACSOD-03 | Head of Service EconomicsPolicy approver and gate approver | AI GBS & Global Business ServicesCost-to-Serve Management | A. Approved 3 policy items: GB11-POL-200, GB11-POL-201, GB11-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-04-9BE269F2SOD-04 | Tower Lead, Hire-to-RetireSub-function owner and rating attester | AI GBS & Global Business ServicesH2R Control Tower | A. Owns 12 agents running at autonomy level 78 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 2026-09-12 | Mitigated |
| SOD-04-05AEDEF5SOD-04 | Tower Lead, Source-to-PaySub-function owner and rating attester | AI GBS & Global Business ServicesS2P Control Tower | A. Owns 12 agents running at autonomy level 85 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-51ECE3FCSOD-04 | Tower Lead, Order-to-CashSub-function owner and rating attester | AI GBS & Global Business ServicesO2C Control Tower | A. Owns 12 agents running at autonomy level 84 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-DD55BC4CSOD-04 | Tower Lead, Record-to-ReportSub-function owner and rating attester | AI GBS & Global Business ServicesR2R Control Tower | A. Owns 12 agents running at autonomy level 79 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-19FCAF72SOD-04 | Head of AutomationSub-function owner and rating attester | AI GBS & Global Business ServicesAutomation Factory | A. Owns 11 agents running at autonomy level 68 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-948CDD61SOD-04 | Head of Master DataSub-function owner and rating attester | AI GBS & Global Business ServicesMaster Data Management | A. Owns 11 agents running at autonomy level 79 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-06-0C730FC3SOD-06 | Platform Engineering LeadControl owner and tester | AI Business ServicesProduction and sandbox estates stay separate | A. Owns control CTL-018 — Production and sandbox estates stay separate B. The test on record was performed by Platform Engineering Lead (own team), inside the owner's own organization | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. moredue 2026-09-18 | In remediation |
| SOD-06-856B7F79SOD-06 | Group Financial ControllerControl owner and tester | AI Business ServicesCost to serve including inference is reconciled | A. Owns control CTL-023 — Cost to serve including inference is reconciled B. The test on record was performed by Group Financial Controller (own team), inside the owner's own organization | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-09-19 | 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.