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.
Rules in force
6
1 enforced by refusal, the rest detective
Conflicts on the books
385
Standing register, triaged
Detected live
385
Recomputed from the estate on this page load
Unowned
291
Found, named, and nobody has been given the fix
In remediation
60
Owner and date assigned
People affected
160
Across 14 functions
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. If the person who asks for something is the person who says yes to it, no amount of evidence afterwards makes the decision independent.
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. This is the most common structural conflict in a shared-service estate.
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. It may still be right; it is not independent.
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. A cap you set for yourself is not a cap.
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. One person on eight conflicts is a different problem from eight people on one each.
VP Revenue Operations5
Director, Legal Operations5
Director, Demand Development3
Director, Sales Enablement3
Director, Sales Compensation3
Director, Market Intelligence3
VP Demand Generation3
Director, Content3
Conflict register
153 matching, showing up to 120
| Reference | Holder | Where | Both sides | Owner and fix | State |
|---|---|---|---|---|---|
| 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 OperationsStation 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-02-A504E4CBSOD-02 | VP BrandStation owner and gate approver | MarketingBrand & Positioning | A. Owns 3 stations on line MK1A B. Approves the same 3 gates: CMO ratify, Owner review, Leader review | No owner assigned | Detected, unowned |
| SOD-02-F45431FESOD-02 | Director, Market IntelligenceStation owner and gate approver | MarketingMarket & Competitive Intelligence | A. Owns 3 stations on line MK2C B. Approves the same 3 gates: SME review, Leader review, Ratify | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-09-15 | In remediation |
| SOD-02-B934EB80SOD-02 | VP Demand GenerationStation owner and gate approver | MarketingDemand Generation | A. Owns 3 stations on line MK3A B. Approves the same 3 gates: Legal check, Launch, Flag anomaly | No owner assigned | Detected, unowned |
| SOD-02-383D709ESOD-02 | Director, ContentStation owner and gate approver | MarketingContent Studio | A. Owns 4 stations on line MK4B B. Approves the same 4 gates: Market review, SME review, Publish and others | No owner assigned | Detected, unowned |
| SOD-02-78FB7177SOD-02 | Director, Campaign OperationsStation owner and gate approver | MarketingCampaign Orchestration | A. Owns 2 stations on line MK5A B. Approves the same 2 gates: Launch, Notify | No owner assigned | Detected, unowned |
| SOD-02-4D98DFC2SOD-02 | Director, Digital ExperienceStation owner and gate approver | MarketingDigital & Web | A. Owns 3 stations on line MK6C B. Approves the same 3 gates: Notify, Approve, Decide | 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 |
| SOD-02-B1BE8022SOD-02 | VP Product MarketingStation owner and gate approver | MarketingProduct Marketing | A. Owns 4 stations on line MK7A B. Approves the same 4 gates: Go decision, Readiness review, Ratify and others | No owner assigned | Detected, unowned |
| SOD-02-4470292FSOD-02 | Director, Field MarketingStation owner and gate approver | MarketingField & Events | A. Owns 2 stations on line MK8A B. Approves the same 2 gates: Budget approve, Leader review | No owner assigned | Detected, unowned |
| SOD-02-CC103352SOD-02 | Director, Customer AdvocacyStation owner and gate approver | MarketingCustomer Advocacy | A. Owns 5 stations on line MK9C B. Approves the same 5 gates: Escalate negative, Legal clear, Secure consent and others | No owner assigned | Detected, unowned |
| SOD-02-BA4D8BC3SOD-02 | Director, Marketing OperationsStation owner and gate approver | MarketingMarketing Ops & MarTech | A. Owns 3 stations on line MK10C B. Approves the same 3 gates: Privacy review, Change board approve, Steward review | No owner assigned | Detected, unowned |
| SOD-02-0A08B1EBSOD-02 | Director, Marketing AnalyticsStation owner and gate approver | MarketingAttribution & Analytics | A. Owns 3 stations on line MK11C B. Approves the same 3 gates: CMO ratify, Ratify, Leader review | No owner assigned | Detected, unowned |
| SOD-02-01214880SOD-02 | Director, Revenue DataStation owner and gate approver | Revenue OperationsCRM Data Stewardship | A. Owns 3 stations on line RO1B B. Approves the same 3 gates: Approve, Steward review, Owner review | No owner assigned | Detected, unowned |
| SOD-02-E6C330B1SOD-02 | VP PricingStation owner and gate approver | Revenue OperationsPricing & Rate Cards | A. Owns 4 stations on line RO2B B. Approves the same 4 gates: Approve, Legal check, Pricing council approve and others | No owner assigned | Detected, unowned |
| SOD-02-2DED8DDDSOD-02 | Director, Quote OperationsStation owner and gate approver | Revenue OperationsQuote-to-Order | A. Owns 3 stations on line RO3A B. Approves the same 3 gates: Route approvals, Countersign, Approve | No owner assigned | Detected, unowned |
| SOD-02-C27CCA31SOD-02 | Director, Order ManagementStation owner and gate approver | Revenue OperationsBooking & Order Management | A. Owns 2 stations on line RO4C B. Approves the same 2 gates: Leader review, Human resolve | 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 | Mitigated |
| SOD-02-80CC5D2CSOD-02 | Director, Billing OperationsStation owner and gate approver | Revenue OperationsBilling Interlock | A. Owns 3 stations on line RO5A B. Approves the same 3 gates: Exception hold, Flag material, Approve above threshold | No owner assigned | Detected, unowned |
| SOD-02-5F213DDBSOD-02 | Director, Revenue AccountingStation owner and gate approver | Revenue OperationsRevenue Recognition Interlock | A. Owns 3 stations on line RO6B B. Approves the same 3 gates: Controller approve, Controller sign, Controller review | No owner assigned | Detected, unowned |
| SOD-02-B374BA21SOD-02 | Director, Renewal OperationsStation owner and gate approver | Revenue OperationsRenewals & Churn Ops | A. Owns 2 stations on line RO7B B. Approves the same 2 gates: Save attempt, Leader review | No owner assigned | Detected, unowned |
| SOD-02-64FD34A1SOD-02 | Director, Sales OperationsStation owner and gate approver | Revenue OperationsTerritory & Comp Ops | A. Owns 3 stations on line RO8C B. Approves the same 3 gates: Sign-off, Approve, Escalate ambiguity | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-10-02 | Mitigated |
| SOD-02-5282F7D9SOD-02 | VP Revenue OperationsStation owner and gate approver | Revenue OperationsForecast Integrity | A. Owns 2 stations on line RO9B B. Approves the same 2 gates: Leader review, Leader readout | No owner assigned | Detected, unowned |
| SOD-02-B3E2A8E9SOD-02 | Director, Revenue SystemsStation owner and gate approver | Revenue OperationsSystems & Integration | A. Owns 3 stations on line RO10B B. Approves the same 3 gates: Change board approve, Escalate, Owner attest | No owner assigned | Detected, unowned |
| SOD-02-EAA5221BSOD-02 | VP Revenue AnalyticsStation owner and gate approver | Revenue OperationsRevenue Analytics | A. Owns 4 stations on line RO11C B. Approves the same 4 gates: Ratify, Finance review, Revenue chief sign and others | No owner assigned | Detected, unowned |
| SOD-02-AE7CD4F2SOD-02 | Director, Commercial ContractsStation owner and gate approver | LegalContract Lifecycle | A. Owns 5 stations on line LG1C B. Approves the same 5 gates: Escalate breach risk, Counsel review, Business approve and others | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-08-27 | In remediation |
| 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-02-9E152C90SOD-02 | VP Category ManagementStation owner and gate approver | Procurement & Source-to-PayCategory Strategy | A. Owns 3 stations on line PR1B B. Approves the same 3 gates: Ratify, Leader review, Council ratify | No owner assigned | Detected, unowned |
| SOD-02-8418FC40SOD-02 | Director, Procurement AnalyticsStation owner and gate approver | Procurement & Source-to-PaySpend Analytics | A. Owns 3 stations on line PR2B B. Approves the same 3 gates: Escalate repeat, Leader review, Flag unclassified | No owner assigned | Detected, unowned |
| SOD-02-7A590ABASOD-02 | Director, Strategic SourcingStation owner and gate approver | Procurement & Source-to-PaySourcing & RFx | A. Owns 4 stations on line PR3A B. Approves the same 4 gates: Award decision, Approve scope, Escalate and others | No owner assigned | Detected, unowned |
| SOD-02-F983C7A6SOD-02 | VP SourcingStation owner and gate approver | Procurement & Source-to-PayNegotiation & Award | A. Owns 4 stations on line PR4B B. Approves the same 4 gates: Approve, Set walk-away, Award and others | No owner assigned | Detected, unowned |
| SOD-02-AAAE9795SOD-02 | Director, Contract ManagementStation owner and gate approver | Procurement & Source-to-PayContract Execution | A. Owns 5 stations on line PR5B B. Approves the same 5 gates: Approve, Legal check, Owner decision and others | No owner assigned | Detected, unowned |
| SOD-02-C0F82070SOD-02 | Director, Supplier ManagementStation owner and gate approver | Procurement & Source-to-PaySupplier Onboarding | A. Owns 4 stations on line PR6A B. Approves the same 4 gates: Approve, Verify bank details, Approve and others | No owner assigned | Detected, unowned |
| SOD-02-5EE0AA39SOD-02 | Director, Supplier RiskStation owner and gate approver | Procurement & Source-to-PaySupplier Performance & Risk | A. Owns 4 stations on line PR7C B. Approves the same 4 gates: Legal review, Leadership approve, Alert owner and others | No owner assigned | Detected, unowned |
| SOD-02-A7670EFFSOD-02 | Director, Procurement OperationsStation owner and gate approver | Procurement & Source-to-PayRequisition & PO | A. Owns 3 stations on line PR8B B. Approves the same 3 gates: Approve, Approve above threshold, Route approval | No owner assigned | Detected, unowned |
| SOD-02-EEC3E105SOD-02 | Director, Accounts Payable OperationsStation owner and gate approver | Procurement & Source-to-PayInvoice & Three-Way Match | A. Owns 4 stations on line PR9A B. Approves the same 4 gates: Resolve, Release or reject, Analyst review and others | No owner assigned | Detected, unowned |
| SOD-02-59EF9C65SOD-02 | Director, Payment OperationsStation owner and gate approver | Procurement & Source-to-PayPayment Interlock | A. Owns 4 stations on line PR10B B. Approves the same 4 gates: Dual approve, Treasury check, Approve run and others | No owner assigned | Detected, unowned |
| SOD-02-C231D3FCSOD-02 | Director, Value AssuranceStation owner and gate approver | Procurement & Source-to-PaySavings Assurance | A. Owns 4 stations on line PR11B B. Approves the same 4 gates: Recover, Approve, Finance validate and others | 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 2026-09-17 | In remediation |
| SOD-02-BC8F8C4FSOD-02 | Director, Demand PlanningStation owner and gate approver | Supply ChainDemand Planning | A. Owns 3 stations on line SC1B B. Approves the same 3 gates: Escalate outside band, Leader review, Planner review | No owner assigned | Detected, unowned |
| SOD-02-44E3FD17SOD-02 | Director, Supply PlanningStation owner and gate approver | Supply ChainSupply Planning | A. Owns 3 stations on line SC2B B. Approves the same 3 gates: Escalate cost, Planner review, Leader decide | No owner assigned | Detected, unowned |
| SOD-02-F5269E2DSOD-02 | VP Integrated Business PlanningStation owner and gate approver | Supply ChainSales & Operations Planning | A. Owns 4 stations on line SC3B B. Approves the same 4 gates: Leader review, Ratify, Executive review and others | No owner assigned | Detected, unowned |
| SOD-02-87AB3373SOD-02 | Director, Inventory ManagementStation owner and gate approver | Supply ChainInventory Optimization | A. Owns 2 stations on line SC4C B. Approves the same 2 gates: Finance approve write-down, Approve above threshold | No owner assigned | Detected, unowned |
| SOD-02-7DE16FF1SOD-02 | Director, LogisticsStation owner and gate approver | Supply ChainLogistics & Transportation | A. Owns 2 stations on line SC5C B. Approves the same 2 gates: Leader review, Analyst review | No owner assigned | Detected, unowned |
| SOD-02-1F2521F6SOD-02 | Director, Fulfillment OperationsStation owner and gate approver | Supply ChainWarehouse & Fulfillment | A. Owns 1 station on line SC6B B. Approves the same 1 gate: Investigate variance | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-09-23 | In remediation |
| SOD-02-0F6BE49CSOD-02 | Director, Global TradeStation owner and gate approver | Supply ChainTrade & Customs | A. Owns 2 stations on line SC7B B. Approves the same 2 gates: Specialist review, Legal review | 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-02-4CBAD91BSOD-02 | Director, Supplier CollaborationStation owner and gate approver | Supply ChainSupplier Collaboration | A. Owns 3 stations on line SC8A B. Approves the same 3 gates: Negotiate, Notify planner, Conduct | No owner assigned | Detected, unowned |
| SOD-02-F29C9CB9SOD-02 | Director, Order PromisingStation owner and gate approver | Supply ChainOrder Promising | A. Owns 2 stations on line SC9B B. Approves the same 2 gates: Owner approve, Leader review | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. Target is every clearance carrying two names by the end of the quarter.due 2026-09-26 | Mitigated |
| SOD-02-F521AF34SOD-02 | VP Supply Chain StrategyStation owner and gate approver | Supply ChainNetwork Design | A. Owns 4 stations on line SC10C B. Approves the same 4 gates: Leader review, Board approve, Approve study and others | No owner assigned | Detected, unowned |
| SOD-02-09931A0BSOD-02 | Director, Supply ResilienceStation owner and gate approver | Supply ChainResilience & Risk | A. Owns 4 stations on line SC11C B. Approves the same 4 gates: Ratify, Stand down, Activate playbook and others | No owner assigned | Detected, unowned |
| SOD-02-01FA0556SOD-02 | VP Engineering OperationsStation owner and gate approver | EngineeringPortfolio & Intake | A. Owns 4 stations on line EN1A B. Approves the same 4 gates: Commit to sprint, Prioritization forum, Leader review and others | 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 | In remediation |
| SOD-02-BC97F1D4SOD-02 | Chief ArchitectStation owner and gate approver | EngineeringArchitecture & Design | A. Owns 3 stations on line EN2A B. Approves the same 3 gates: Review board ratify, Owner review, CTO ratify | No owner assigned | Detected, unowned |
| SOD-02-9630F1E2SOD-02 | Director, Platform EngineeringStation owner and gate approver | EngineeringBuild | A. Owns 4 stations on line EN3A B. Approves the same 4 gates: Human review, Merge, Escalate and others | No owner assigned | Detected, unowned |
| SOD-02-4CF437D4SOD-02 | Director, Engineering QualityStation owner and gate approver | EngineeringCode Review & Quality | A. Owns 5 stations on line EN4A B. Approves the same 5 gates: Merge, Human review, Ratify and others | No owner assigned | Detected, unowned |
| SOD-02-754CF120SOD-02 | Director, Quality EngineeringStation owner and gate approver | EngineeringTest & Assurance | A. Owns 3 stations on line EN5A B. Approves the same 3 gates: Escalate blocker, Sign quality gate, Flag regression | 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 2026-10-03 | Mitigated |
| SOD-02-CBB93CDDSOD-02 | Director, Release EngineeringStation owner and gate approver | EngineeringRelease & Deployment | A. Owns 3 stations on line EN6A B. Approves the same 3 gates: Change board approve, Release manager sign, Notify | No owner assigned | Detected, unowned |
| SOD-02-623C7D6BSOD-02 | Director, Site ReliabilityStation owner and gate approver | EngineeringSite Reliability | A. Owns 3 stations on line EN7C B. Approves the same 3 gates: Escalate cost, Freeze releases, Escalate to human commander | No owner assigned | Detected, unowned |
| SOD-02-C5E3811ASOD-02 | Director, Engineering EffectivenessStation owner and gate approver | EngineeringTechnical Debt | A. Owns 3 stations on line EN8A B. Approves the same 3 gates: Owner accept, Escalate holdout, Ratify | No owner assigned | Detected, unowned |
| SOD-02-7183E7E6SOD-02 | Director, Developer PlatformStation owner and gate approver | EngineeringDeveloper Experience | A. Owns 2 stations on line EN9B B. Approves the same 2 gates: Owner accept, Manager confirm | No owner assigned | Detected, unowned |
| SOD-02-202F9BE7SOD-02 | Director, Security EngineeringStation owner and gate approver | EngineeringSecurity Engineering | A. Owns 4 stations on line EN10A B. Approves the same 4 gates: Escalate critical, Close, Notify and others | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. Target is every clearance carrying two names by the end of the quarter.due 2026-08-29 | In remediation |
| SOD-02-CA4010D3SOD-02 | Director, Engineering AnalyticsStation owner and gate approver | EngineeringEngineering Analytics | A. Owns 3 stations on line EN11A B. Approves the same 3 gates: CTO review, Ratify, Owner review | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-08-30 | Mitigated |
| SOD-02-E084960FSOD-02 | Director, Discovery ResearchStation owner and gate approver | Research & DevelopmentDiscovery Research | A. Owns 2 stations on line RD1A B. Approves the same 2 gates: Scientist review, Chief Scientist ratify | No owner assigned | Detected, unowned |
| SOD-02-D8C70F83SOD-02 | VP InnovationStation owner and gate approver | Research & DevelopmentInnovation Portfolio | A. Owns 4 stations on line RD2C B. Approves the same 4 gates: ExCo ratify, Gate committee decide, Fund or stop and others | No owner assigned | Detected, unowned |
| SOD-02-9C9C3513SOD-02 | Director, Research MethodsStation owner and gate approver | Research & DevelopmentExperiment Design | A. Owns 4 stations on line RD3C B. Approves the same 4 gates: Council approve, Scientist review, Ethics clearance and others | No owner assigned | Detected, unowned |
| SOD-02-3162A141SOD-02 | Director, Laboratory OperationsStation owner and gate approver | Research & DevelopmentLab Operations | A. Owns 1 station on line RD4C B. Approves the same 1 gate: Technician sign | No owner assigned | Detected, unowned |
| SOD-02-769E2CEFSOD-02 | Director, Data ScienceStation owner and gate approver | Research & DevelopmentData Science & Modeling | A. Owns 4 stations on line RD5B B. Approves the same 4 gates: Approve promotion, Deploy, Reviewer approve and others | No owner assigned | Detected, unowned |
| SOD-02-54CA1511SOD-02 | Director, Product DevelopmentStation owner and gate approver | Research & DevelopmentPrototype & Pilot | A. Owns 4 stations on line RD6A B. Approves the same 4 gates: Readiness review, Scale decision, Approve pilot and others | No owner assigned | Detected, unowned |
| SOD-02-25E919E1SOD-02 | Director, IP CaptureStation owner and gate approver | Research & DevelopmentIP Creation & Capture | A. Owns 3 stations on line RD7A B. Approves the same 3 gates: Inventor confirm, Ratify, Owner attest | No owner assigned | Detected, unowned |
| SOD-02-C318B6A9SOD-02 | VP Regulatory ScienceStation owner and gate approver | Research & DevelopmentRegulatory Science | A. Owns 6 stations on line RD8B B. Approves the same 6 gates: Owner accept, Officer sign, Scientist 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-A68705E7SOD-02 | Director, External InnovationStation owner and gate approver | Research & DevelopmentExternal Collaboration | A. Owns 6 stations on line RD9C B. Approves the same 6 gates: Approve, Counsel review, Sign 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 | In remediation |
| SOD-02-59C76E6DSOD-02 | Director, Technology ScoutingStation owner and gate approver | Research & DevelopmentTechnology Scouting | A. Owns 3 stations on line RD10C B. Approves the same 3 gates: Leader review, Leader review, Ratify | No owner assigned | Detected, unowned |
| SOD-02-6F4E6DE3SOD-02 | Director, R&D AnalyticsStation owner and gate approver | Research & DevelopmentPortfolio Analytics | A. Owns 3 stations on line RD11A B. Approves the same 3 gates: Leader review, Ratify, Leader review | No owner assigned | Detected, unowned |
| SOD-02-F34493ADSOD-02 | VP Financial Planning & AnalysisStation owner and gate approver | FinanceFP&A & Planning | A. Owns 4 stations on line FI1C B. Approves the same 4 gates: ExCo ratify, Business partner review, CFO review and others | No owner assigned | Detected, unowned |
| SOD-02-C517A1F1SOD-02 | Director, BudgetingStation owner and gate approver | FinanceBudgeting & Forecasting | A. Owns 5 stations on line FI2A B. Approves the same 5 gates: Executive approve, Board approve, Challenge sessions and others | No owner assigned | Detected, unowned |
| SOD-02-35AEC400SOD-02 | Director, Management ReportingStation owner and gate approver | FinanceManagement Reporting | A. Owns 3 stations on line FI3B B. Approves the same 3 gates: Escalate ambiguity, Controller review, Owner confirm | No owner assigned | Detected, unowned |
| SOD-02-90D1878FSOD-02 | Corporate ControllerStation owner and gate approver | FinanceRecord-to-Report & Close | A. Owns 5 stations on line FI4A B. Approves the same 5 gates: Controller sign, Exception review, Reviewer approve and others | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. Target is every clearance carrying two names by the end of the quarter.due 2026-09-14 | Mitigated |
| SOD-02-522D2A14SOD-02 | Chief Accounting OfficerStation owner and gate approver | FinanceControllership & Policy | A. Owns 4 stations on line FI5B B. Approves the same 4 gates: Controller review, Auditor concur, Controller ratify and others | No owner assigned | Detected, unowned |
| SOD-02-89449336SOD-02 | Corporate TreasurerStation owner and gate approver | FinanceTreasury & Cash | A. Owns 5 stations on line FI6B B. Approves the same 5 gates: Execute, Treasurer approve, Treasurer approve and others | No owner assigned | Detected, unowned |
| SOD-02-9BEFF431SOD-02 | VP TaxStation owner and gate approver | FinanceTax | A. Owns 5 stations on line FI7A B. Approves the same 5 gates: Controller sign, Tax director review, Counsel concur and others | 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 2026-09-17 | In remediation |
| SOD-02-22BD348CSOD-02 | Director, Internal ControlsStation owner and gate approver | FinanceInternal Controls & Audit Interlock | A. Owns 4 stations on line FI8B B. Approves the same 4 gates: Controller review, Deficiency raise, Sign and others | No owner assigned | Detected, unowned |
| SOD-02-AA2C258ASOD-02 | VP Investor RelationsStation owner and gate approver | FinanceInvestor Relations Support | A. Owns 5 stations on line FI9B B. Approves the same 5 gates: IR officer review, Legal review, CFO approve and others | 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 |
| SOD-02-87727F7FSOD-02 | Director, Profitability AnalyticsStation owner and gate approver | FinanceCost & Profitability | A. Owns 3 stations on line FI10C B. Approves the same 3 gates: CFO ratify, Ratify, Leader review | No owner assigned | Detected, unowned |
| SOD-02-69F454DASOD-02 | Director, Finance SystemsStation owner and gate approver | FinanceFinance Systems | A. Owns 3 stations on line FI11A B. Approves the same 3 gates: Approve, Escalate, Change board approve | No owner assigned | Detected, unowned |
| SOD-02-35A3D72ASOD-02 | VP Workforce StrategyStation owner and gate approver | Human ResourcesStrategic Workforce Planning | A. Owns 3 stations on line HR1B B. Approves the same 3 gates: Ratify, Ratify, Ratify | No owner assigned | Detected, unowned |
| SOD-02-F9E50AEBSOD-02 | VP Talent AcquisitionStation owner and gate approver | Human ResourcesTalent Acquisition | A. Owns 3 stations on line HR2D B. Approves the same 3 gates: Ratify, Offer approve, Approve req | No owner assigned | Detected, unowned |
| SOD-02-2270F67BSOD-02 | Director, Employee ExperienceStation owner and gate approver | Human ResourcesOnboarding | A. Owns 1 station on line HR3A B. Approves the same 1 gate: Right-to-work check | No owner assigned | Detected, unowned |
| SOD-02-15C3BC6CSOD-02 | VP HR Business PartneringStation owner and gate approver | Human ResourcesHR Business Partnering | A. Owns 5 stations on line HR4A B. Approves the same 5 gates: Judgment review, Works council check, Ratify and others | No owner assigned | Detected, unowned |
| SOD-02-6DAD8B88SOD-02 | Director, Performance & TalentStation owner and gate approver | Human ResourcesPerformance Management | A. Owns 6 stations on line HR5B B. Approves the same 6 gates: Calibration session, Rating lock, Legal check and others | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. Target is every clearance carrying two names by the end of the quarter.due 2026-09-26 | Mitigated |
| SOD-02-E8FEEE58SOD-02 | Director, Learning & CapabilityStation owner and gate approver | Human ResourcesLearning & Development | A. Owns 4 stations on line HR6C B. Approves the same 4 gates: Publish, SME review, Escalate non-completion and others | No owner assigned | Detected, unowned |
| SOD-02-3C846520SOD-02 | Director, Global MobilityStation owner and gate approver | Human ResourcesTalent Mobility | A. Owns 5 stations on line HR7C B. Approves the same 5 gates: Leader review, Manager consult, Offer internal and others | No owner assigned | Detected, unowned |
| SOD-02-128C8CCFSOD-02 | VP Total RewardsStation owner and gate approver | Human ResourcesTotal Rewards | A. Owns 6 stations on line HR8C B. Approves the same 6 gates: Approve, Exception review, Set budget and others | No owner assigned | Detected, unowned |
| SOD-02-AA390175SOD-02 | Director, Employee RelationsStation owner and gate approver | Human ResourcesExit Management | A. Owns 6 stations on line HR9C B. Approves the same 6 gates: Works council, Legal review, Leadership ratify and others | No owner assigned | Detected, unowned |
| SOD-02-29219815SOD-02 | Director, Culture & EngagementStation owner and gate approver | Human ResourcesCulture & Engagement | A. Owns 4 stations on line HR10C B. Approves the same 4 gates: Ratify, Leader alert, Works council clear and others | No owner assigned | Detected, unowned |
| SOD-02-AA74F471SOD-02 | Director, HR TechnologyStation owner and gate approver | Human ResourcesHR AI-IT | A. Owns 4 stations on line HR11B B. Approves the same 4 gates: CAB approve, Steward review, Promote level and others | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-10-02 | In remediation |
| SOD-02-7BF3F095SOD-02 | Director, Service DeskStation owner and gate approver | Information TechnologyService Desk | A. Owns 1 station on line IT1C B. Approves the same 1 gate: Notify owner | No owner assigned | Detected, unowned |
| SOD-02-7FB6F3C4SOD-02 | Director, Identity & Access ManagementStation owner and gate approver | Information TechnologyIdentity & Access | A. Owns 2 stations on line IT2A B. Approves the same 2 gates: Manager approve exception, Owner approve | No owner assigned | Detected, unowned |
| SOD-02-7504B0BBSOD-02 | Director, Workplace TechnologyStation owner and gate approver | Information TechnologyEnd-User Compute | A. Owns 2 stations on line IT3C B. Approves the same 2 gates: Approve, Escalate holdout | No owner assigned | Detected, unowned |
| SOD-02-8D70B4C5SOD-02 | Director, Cloud InfrastructureStation owner and gate approver | Information TechnologyInfrastructure & Cloud | A. Owns 3 stations on line IT4A B. Approves the same 3 gates: Escalate spend, Owner approve, Flag failure | 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-D2185156SOD-02 | Director, Network ServicesStation owner and gate approver | Information TechnologyNetwork | A. Owns 3 stations on line IT5A B. Approves the same 3 gates: Escalate, Change board approve, Peer review | No owner assigned | Detected, unowned |
| SOD-02-EA2C7C4ASOD-02 | Director, Application ServicesStation owner and gate approver | Information TechnologyApplication Management | A. Owns 3 stations on line IT6B B. Approves the same 3 gates: Change board approve, Human escalate, Business owner approve | No owner assigned | Detected, unowned |
| SOD-02-69E55356SOD-02 | Director, Security OperationsStation owner and gate approver | Information TechnologyCybersecurity Operations | A. Owns 6 stations on line IT7A B. Approves the same 6 gates: Escalate incident, Analyst review, Declare and others | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-08-30 | In remediation |
| SOD-02-F89BFC0ASOD-02 | Director, Data PlatformStation owner and gate approver | Information TechnologyData & Integration Platform | A. Owns 3 stations on line IT8B B. Approves the same 3 gates: Owner approve, Escalate, Steward approve | No owner assigned | Detected, unowned |
| SOD-02-DB7EC3DCSOD-02 | Director, IT Asset ManagementStation owner and gate approver | Information TechnologyAsset & License | A. Owns 5 stations on line IT9C B. Approves the same 5 gates: Respond, Legal review, Owner approve and others | 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 2026-09-01 | In remediation |
| SOD-02-C446CCC5SOD-02 | Director, Change ManagementStation owner and gate approver | Information TechnologyChange & Release | A. Owns 3 stations on line IT10B B. Approves the same 3 gates: Change board approve, Declare, Retrospective approve | 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.
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.
5
Decide whether a detective rule should block
These rules report a conflict after the fact instead of preventing it.
2
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
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. 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.
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. Every conflict the detector finds is on the register.