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 sales · clear
| Reference | Holder | Where | Both sides | Owner and fix | State |
|---|---|---|---|---|---|
| SOD-01-3B5CC111SOD-01 | M. ReyesItem owner and raiser | SalesProposal assembly — Halstead expansion | A. Raised SLS-4823 — Proposal assembly — Halstead expansion B. Holds the decision on SLS-4823 in the same queue | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-08-26 | Mitigated |
| SOD-01-3E5CC5CASOD-01 | Sales CoSItem owner and raiser | SalesCRM reconciliation — EMEA mid-market | A. Raised SLS-4826 — CRM reconciliation — EMEA mid-market B. Holds the decision on SLS-4826 in the same queue | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-08-27 | Mitigated |
| SOD-02-20D490FBSOD-02 | VP Sales StrategyStation owner and gate approver | SalesTerritory & Quota Planning | A. Owns 4 stations on line SL1A B. Approves the same 4 gates: Leader review, Ratify, Approve and others | No owner assigned | Detected, unowned |
| SOD-02-B366DD90SOD-02 | VP Strategic AccountsStation owner and gate approver | SalesAccount Planning | A. Owns 4 stations on line SL2A B. Approves the same 4 gates: Rep review, Ratify, Leader review and others | No owner assigned | Detected, unowned |
| SOD-02-8E05BC7ESOD-02 | Director, Demand DevelopmentStation owner and gate approver | SalesDemand Qualification | A. Owns 1 station on line SL3A B. Approves the same 1 gate: Accept | No owner assigned | Detected, unowned |
| SOD-02-D5726660SOD-02 | VP Sales OperationsStation owner and gate approver | SalesOpportunity Management | A. Owns 4 stations on line SL4A B. Approves the same 4 gates: Commit, Advance, Seller review and others | No owner assigned | Detected, unowned |
| SOD-02-3C941D8ASOD-02 | Director, Solution ConsultingStation owner and gate approver | SalesSolution & Proposal | A. Owns 4 stations on line SL5A B. Approves the same 4 gates: Bid decision, Legal check, Seller review and others | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-09-07 | In remediation |
| SOD-02-0327E1A3SOD-02 | Director, Deal DeskStation owner and gate approver | SalesDeal Desk & Approvals | A. Owns 4 stations on line SL6A B. Approves the same 4 gates: Finance approve, Legal approve, Policy owner review and others | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-09-08 | Mitigated |
| SOD-02-4EAACCABSOD-02 | VP Revenue Growth ManagementStation owner and gate approver | SalesForecast & Pipeline Hygiene | A. Owns 4 stations on line SL7A B. Approves the same 4 gates: Lock commit, Leader call, Escalate stale and others | No owner assigned | Detected, unowned |
| SOD-02-D6AB274ASOD-02 | VP Partners & AlliancesStation owner and gate approver | SalesPartner & Channel | A. Owns 2 stations on line SL8A B. Approves the same 2 gates: Approve, Leader decision | No owner assigned | Detected, unowned |
| SOD-02-DCA7116BSOD-02 | VP Customer GrowthStation owner and gate approver | SalesExpansion & Renewals | A. Owns 2 stations on line SL9A B. Approves the same 2 gates: Rep review, Approve concession | No owner assigned | Detected, unowned |
| SOD-02-0148BFF4SOD-02 | Director, Sales EnablementStation owner and gate approver | SalesSales Enablement | A. Owns 3 stations on line SL10A B. Approves the same 3 gates: Certify, Leader approve, Manager review | No owner assigned | Detected, unowned |
| SOD-02-F88A5F1FSOD-02 | Director, Sales CompensationStation owner and gate approver | SalesIncentive Compensation | A. Owns 4 stations on line SL11A B. Approves the same 4 gates: Approve, Controller review, Decision and others | No owner assigned | Detected, unowned |
| SOD-03-8224C498SOD-03 | VP Sales StrategyPolicy approver and gate approver | SalesTerritory & Quota Planning | A. Approved 2 policy items: SL1-POL-201, SL1-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-09C4AA53SOD-03 | VP Strategic AccountsPolicy approver and gate approver | SalesAccount Planning | A. Approved 3 policy items: SL2-POL-201, SL2-POL-202, SL2-POL-200 B. Also approves gates on the lines those policies bind | 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 2026-08-28 | Mitigated |
| SOD-03-DDC06E43SOD-03 | Director, Demand DevelopmentPolicy approver and gate approver | SalesDemand Qualification | A. Approved 3 policy items: SL3-POL-201, SL3-POL-202, SL3-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-FDC9359FSOD-03 | VP Sales OperationsPolicy approver and gate approver | SalesOpportunity Management | A. Approved 2 policy items: SL4-POL-201, SL4-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-0F283A33SOD-03 | Director, Solution ConsultingPolicy approver and gate approver | SalesSolution & Proposal | A. Approved 4 policy items: SL5-POL-200, SL5-POL-202, SL5-POL-201, SL5-POL-203 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-F3831CBASOD-03 | Director, Deal DeskPolicy approver and gate approver | SalesDeal Desk & Approvals | A. Approved 3 policy items: SL6-POL-201, SL6-POL-200, SL6-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-782EACD2SOD-03 | VP Revenue Growth ManagementPolicy approver and gate approver | SalesForecast & Pipeline Hygiene | A. Approved 4 policy items: SL7-POL-201, SL7-POL-203, SL7-POL-200, SL7-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-12741D73SOD-03 | VP Partners & AlliancesPolicy approver and gate approver | SalesPartner & Channel | A. Approved 2 policy items: SL8-POL-200, SL8-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-2A597852SOD-03 | VP Customer GrowthPolicy approver and gate approver | SalesExpansion & Renewals | A. Approved 4 policy items: SL9-POL-200, SL9-POL-202, SL9-POL-203, SL9-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-3C829769SOD-03 | Director, Sales EnablementPolicy approver and gate approver | SalesSales Enablement | A. Approved 3 policy items: SL10-POL-200, SL10-POL-202, SL10-POL-201 B. Also approves gates on the lines those policies bind | 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 2026-09-05 | In remediation |
| SOD-03-B0222546SOD-03 | Director, Sales CompensationPolicy approver and gate approver | SalesIncentive Compensation | A. Approved 3 policy items: SL11-POL-200, SL11-POL-201, SL11-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-04-5CA578F2SOD-04 | Director, Demand DevelopmentSub-function owner and rating attester | SalesDemand Qualification | A. Owns 9 agents running at autonomy level 83 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-C587AE39SOD-04 | Director, Sales EnablementSub-function owner and rating attester | SalesSales Enablement | A. Owns 9 agents running at autonomy level 75 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 2026-09-30 | Mitigated |
| SOD-04-6785D0B3SOD-04 | Director, Sales CompensationSub-function owner and rating attester | SalesIncentive Compensation | A. Owns 9 agents running at autonomy level 78 B. Stands behind the A estate rating that grades those same agents | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-10-01 | 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.