Separation of concerns
Segregation of duties
Six duty pairs that should not sit in one pair of hands. The register below is not a policy document — it is recomputed against the live estate on every load, so what you see is who holds both sides right now.
Health
Whether incompatible duties are separated
Segregation rules in force, the conflicts detected against them and how many have been mitigated.
The duty pairs
What each rule separates, how it is enforced, and how many holders it currently finds.
The oldest control in existence. If the person who asks for something is the person who says yes to it, no amount of evidence afterwards makes the decision independent.
A gate approved by the person who owns the work upstream of it is a formality. This is the most common structural conflict in a shared-service estate.
Writing the rule and then judging compliance with it collapses two independent checks into one opinion.
A rating signed by the person whose numbers it grades is a self-assessment. It may still be right; it is not independent.
Self-delegation makes the authority register circular. A cap you set for yourself is not a cap.
This is the difference between "we have gates" and "the gates were tested by someone who does not run them".
Who holds both sides most often
Concentration matters more than the raw count. One person on eight conflicts is a different problem from eight people on one each.
Conflict register
19 matching, showing up to 120
| Reference | Holder | Where | Both sides | Owner and fix | State |
|---|---|---|---|---|---|
| SOD-02-0C3940FDSOD-02 | Associate General Counsel, CommercialStation owner and gate approver | LegalCommercial Advisory | A. Owns 3 stations on line LG2B B. Approves the same 3 gates: GC ratify, Counsel review, Counsel approve | No owner assigned | Detected, unowned |
| SOD-02-17CCB16BSOD-02 | Company SecretaryStation owner and gate approver | LegalCorporate & Governance | A. Owns 4 stations on line LG3B B. Approves the same 4 gates: Officer sign, Chair approve, Legal review and others | No owner assigned | Detected, unowned |
| SOD-02-6A6D96FCSOD-02 | Chief Compliance OfficerStation owner and gate approver | LegalCompliance & Ethics | A. Owns 4 stations on line LG4A B. Approves the same 4 gates: Escalate non-completion, Escalate hit, Assign investigator and others | No owner assigned | Detected, unowned |
| SOD-02-FD1B51E5SOD-02 | VP Regulatory AffairsStation owner and gate approver | LegalRegulatory Affairs | A. Owns 4 stations on line LG5B B. Approves the same 4 gates: Counsel review, Officer sign, GC ratify and others | No owner assigned | Detected, unowned |
| SOD-02-E1F0D7E9SOD-02 | Chief IP CounselStation owner and gate approver | LegalIP Portfolio | A. Owns 4 stations on line LG6A B. Approves the same 4 gates: Instruct counsel, Committee decision, Ratify and others | No owner assigned | Detected, unowned |
| SOD-02-1C7629FCSOD-02 | VP LitigationStation owner and gate approver | LegalLitigation & Disputes | A. Owns 6 stations on line LG7B B. Approves the same 6 gates: Privilege check, Produce, Strategy review and others | No owner assigned | Detected, unowned |
| SOD-02-517FC731SOD-02 | Associate General Counsel, EmploymentStation owner and gate approver | LegalEmployment Legal | A. Owns 5 stations on line LG8C B. Approves the same 5 gates: Works council, Counsel ratify, Counsel decision and others | No owner assigned | Detected, unowned |
| SOD-02-1C839402SOD-02 | Data Protection OfficerStation owner and gate approver | LegalPrivacy & Data Protection | A. Owns 6 stations on line LG9A B. Approves the same 6 gates: Privacy review, Privacy review, Sign and others | No owner assigned | Detected, unowned |
| SOD-02-76AFD50ESOD-02 | Director, Legal OperationsStation owner and gate approver | LegalOutside Counsel Management | A. Owns 4 stations on line LG10A B. Approves the same 4 gates: Approve engagement, Counsel review, Approve and others | No owner assigned | Detected, unowned |
| SOD-02-9A7FA630SOD-02 | Director, Legal OperationsStation owner and gate approver | LegalLegal Ops & Spend | A. Owns 3 stations on line LG11A B. Approves the same 3 gates: GC review, Counsel approve, Leader review | No owner assigned | Detected, unowned |
| SOD-03-54EC5EC3SOD-03 | Director, Commercial ContractsPolicy approver and gate approver | LegalContract Lifecycle | A. Approved 2 policy items: LG1-POL-200, LG1-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-F3D52ECCSOD-03 | Associate General Counsel, CommercialPolicy approver and gate approver | LegalCommercial Advisory | A. Approved 3 policy items: LG2-POL-200, LG2-POL-201, LG2-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-50250BA4SOD-03 | Company SecretaryPolicy approver and gate approver | LegalCorporate & Governance | A. Approved 3 policy items: LG3-POL-201, LG3-POL-202, LG3-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-ABC16463SOD-03 | Chief Compliance OfficerPolicy approver and gate approver | LegalCompliance & Ethics | A. Approved 4 policy items: LG4-POL-200, LG4-POL-201, LG4-POL-203, LG4-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-7EFAADF9SOD-03 | VP LitigationPolicy approver and gate approver | LegalLitigation & Disputes | A. Approved 3 policy items: LG7-POL-202, LG7-POL-201, LG7-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-A52AD8CASOD-03 | Associate General Counsel, EmploymentPolicy approver and gate approver | LegalEmployment Legal | A. Approved 2 policy items: LG8-POL-200, LG8-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-5182447BSOD-03 | Data Protection OfficerPolicy approver and gate approver | LegalPrivacy & Data Protection | A. Approved 4 policy items: LG9-POL-200, LG9-POL-203, LG9-POL-201, LG9-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-4C8F1047SOD-03 | Director, Legal OperationsPolicy approver and gate approver | LegalOutside Counsel Management | A. Approved 4 policy items: LG10-POL-202, LG10-POL-203, LG10-POL-201, LG10-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-04-913E67C9SOD-04 | Director, Legal OperationsSub-function owner and rating attester | LegalOutside Counsel Management | A. Owns 8 agents running at autonomy level 79 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
Actions
What is waiting on a person
A separation rule is only real when somebody unwinds the combinations it forbids. Detected means found and not yet touched.
Start unwinding a detected conflict
Found by the rule and nobody has picked it up.
Finish a remediation already underway
Owner named, plan written, not yet closed.
Decide whether a detective rule should block
These rules report a conflict after the fact instead of preventing it.
Escalate a conflict past its date
Past the remediation date on the record and still combining both duties.
Operations
What this desk is allowed to start
A surface that only reports is not operable. This is the work this page can set in motion, and the bound it runs into.
Trigger and bound
This desk can raise, reassign or mitigate a conflict, and it can change a rule between detective and blocking. Only 1 of 6 rules currently block: the rest allow the combination to occur and report it afterwards, which means the desk finds out about a breach rather than preventing it.
Live observability
What the record shows right now
Conflict states across the estate. Mitigated means a compensating control was accepted, not that the combination was removed.
Current distribution
385 conflicts
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. The record does not support that today: 351 combinations are live, 291 of them with nobody assigned, and only 34 have a compensating control accepted. The deeper issue is enforcement. 1 rule of 6 blocks at the point of action; the others are detective, so the platform is describing breaches it allowed rather than preventing them.
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. Every conflict the detector finds is on the register.