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
18 matching, showing up to 120
| Reference | Holder | Where | Both sides | Owner and fix | State |
|---|---|---|---|---|---|
| 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-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-02-4D98DFC2SOD-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-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-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-02-1F2521F6SOD-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-02-01FA0556SOD-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-02-202F9BE7SOD-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-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-02-9BEFF431SOD-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-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-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-02-69E55356SOD-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-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-02-4497B6F8SOD-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. Target is every clearance carrying two names by the end of the quarter.due 2026-09-10 | In remediation |
| 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 |
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.