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-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 OperationsPolicy 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-03-0761ABD4SOD-03 | VP BrandPolicy approver and gate approver | MarketingBrand & Positioning | A. Approved 2 policy items: MK1-POL-200, MK1-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-42C4DF53SOD-03 | Director, Market IntelligencePolicy approver and gate approver | MarketingMarket & Competitive Intelligence | A. Approved 3 policy items: MK2-POL-202, MK2-POL-200, MK2-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-9F6DFE83SOD-03 | VP Demand GenerationPolicy approver and gate approver | MarketingDemand Generation | A. Approved 4 policy items: MK3-POL-201, MK3-POL-203, MK3-POL-200, MK3-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-6AB5EE7DSOD-03 | Director, ContentPolicy approver and gate approver | MarketingContent Studio | A. Approved 4 policy items: MK4-POL-201, MK4-POL-200, MK4-POL-202, MK4-POL-203 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-11AC5BE4SOD-03 | Director, Campaign OperationsPolicy approver and gate approver | MarketingCampaign Orchestration | A. Approved 4 policy items: MK5-POL-202, MK5-POL-203, MK5-POL-201, MK5-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-F873C495SOD-03 | Director, Digital ExperiencePolicy approver and gate approver | MarketingDigital & Web | A. Approved 2 policy items: MK6-POL-200, MK6-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 2026-09-12 | Mitigated |
| SOD-03-D48BBF41SOD-03 | VP Product MarketingPolicy approver and gate approver | MarketingProduct Marketing | A. Approved 2 policy items: MK7-POL-200, MK7-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-02973588SOD-03 | Director, Field MarketingPolicy approver and gate approver | MarketingField & Events | A. Approved 3 policy items: MK8-POL-200, MK8-POL-202, MK8-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-AC12EE5BSOD-03 | Director, Customer AdvocacyPolicy approver and gate approver | MarketingCustomer Advocacy | A. Approved 3 policy items: MK9-POL-200, MK9-POL-202, MK9-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-1216135CSOD-03 | Director, Marketing OperationsPolicy approver and gate approver | MarketingMarketing Ops & MarTech | A. Approved 2 policy items: MK10-POL-200, MK10-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-13103B42SOD-03 | Director, Marketing AnalyticsPolicy approver and gate approver | MarketingAttribution & Analytics | A. Approved 2 policy items: MK11-POL-201, MK11-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 2026-09-17 | Mitigated |
| SOD-03-E17CE417SOD-03 | Director, Revenue DataPolicy approver and gate approver | Revenue OperationsCRM Data Stewardship | A. Approved 2 policy items: RO1-POL-201, RO1-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-6515712ASOD-03 | VP PricingPolicy approver and gate approver | Revenue OperationsPricing & Rate Cards | A. Approved 3 policy items: RO2-POL-200, RO2-POL-201, RO2-POL-202 B. Also approves gates on the lines those policies bind | 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-03-B8F5FE32SOD-03 | Director, Quote OperationsPolicy approver and gate approver | Revenue OperationsQuote-to-Order | A. Approved 3 policy items: RO3-POL-201, RO3-POL-202, RO3-POL-200 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 2026-09-20 | In remediation |
| SOD-03-6422CF0ESOD-03 | Director, Order ManagementPolicy approver and gate approver | Revenue OperationsBooking & Order Management | A. Approved 2 policy items: RO4-POL-201, RO4-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-F5BC58E5SOD-03 | Director, Billing OperationsPolicy approver and gate approver | Revenue OperationsBilling Interlock | A. Approved 2 policy items: RO5-POL-201, RO5-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-3014ACE2SOD-03 | Director, Revenue AccountingPolicy approver and gate approver | Revenue OperationsRevenue Recognition Interlock | A. Approved 3 policy items: RO6-POL-201, RO6-POL-202, RO6-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-4FE66BF6SOD-03 | Director, Renewal OperationsPolicy approver and gate approver | Revenue OperationsRenewals & Churn Ops | A. Approved 2 policy items: RO7-POL-201, RO7-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-50E78AC2SOD-03 | Director, Sales OperationsPolicy approver and gate approver | Revenue OperationsTerritory & Comp Ops | A. Approved 2 policy items: RO8-POL-201, RO8-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-ABF59524SOD-03 | VP Revenue OperationsPolicy approver and gate approver | Revenue OperationsForecast Integrity | A. Approved 3 policy items: RO9-POL-200, RO9-POL-201, RO9-POL-202 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. Target is every clearance carrying two names by the end of the quarter.due 2026-09-26 | Mitigated |
| SOD-03-5DF02636SOD-03 | Director, Revenue SystemsPolicy approver and gate approver | Revenue OperationsSystems & Integration | A. Approved 4 policy items: RO10-POL-202, RO10-POL-203, RO10-POL-200, RO10-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-5791A58ASOD-03 | VP Revenue AnalyticsPolicy approver and gate approver | Revenue OperationsRevenue Analytics | A. Approved 4 policy items: RO11-POL-201, RO11-POL-200, RO11-POL-203, RO11-POL-202 B. Also approves gates on the lines those policies bind | 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-03-668990DESOD-03 | VP Regulatory AffairsPolicy approver and gate approver | LegalRegulatory Affairs | A. Approved 4 policy items: LG5-POL-203, LG5-POL-200, LG5-POL-201, LG5-POL-202 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 2026-10-03 | Mitigated |
| SOD-03-9B72EDC4SOD-03 | Chief IP CounselPolicy approver and gate approver | LegalIP Portfolio | A. Approved 2 policy items: LG6-POL-200, LG6-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. Target is every clearance carrying two names by the end of the quarter.due 2026-08-25 | In remediation |
| 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-03-39EB4E7FSOD-03 | Director, Legal OperationsPolicy approver and gate approver | LegalLegal Ops & Spend | A. Approved 3 policy items: LG11-POL-200, LG11-POL-201, LG11-POL-202 B. Also approves gates on the lines those policies bind | 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-03-6044477FSOD-03 | VP Category ManagementPolicy approver and gate approver | Procurement & Source-to-PayCategory Strategy | A. Approved 2 policy items: PR1-POL-200, PR1-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 2026-08-31 | In remediation |
| SOD-03-D0B6FB89SOD-03 | Director, Procurement AnalyticsPolicy approver and gate approver | Procurement & Source-to-PaySpend Analytics | A. Approved 3 policy items: PR2-POL-200, PR2-POL-202, PR2-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-8D0E3E1FSOD-03 | Director, Strategic SourcingPolicy approver and gate approver | Procurement & Source-to-PaySourcing & RFx | A. Approved 2 policy items: PR3-POL-201, PR3-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-C91FE5FFSOD-03 | VP SourcingPolicy approver and gate approver | Procurement & Source-to-PayNegotiation & Award | A. Approved 3 policy items: PR4-POL-201, PR4-POL-202, PR4-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-824C3AFESOD-03 | Director, Contract ManagementPolicy approver and gate approver | Procurement & Source-to-PayContract Execution | A. Approved 4 policy items: PR5-POL-202, PR5-POL-201, PR5-POL-200, PR5-POL-203 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-25187FFDSOD-03 | Director, Supplier ManagementPolicy approver and gate approver | Procurement & Source-to-PaySupplier Onboarding | A. Approved 4 policy items: PR6-POL-202, PR6-POL-201, PR6-POL-200, PR6-POL-203 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-D988A8D4SOD-03 | Director, Supplier RiskPolicy approver and gate approver | Procurement & Source-to-PaySupplier Performance & Risk | A. Approved 4 policy items: PR7-POL-203, PR7-POL-200, PR7-POL-202, PR7-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-E7DEDEF6SOD-03 | Director, Procurement OperationsPolicy approver and gate approver | Procurement & Source-to-PayRequisition & PO | A. Approved 3 policy items: PR8-POL-200, PR8-POL-201, PR8-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-3C070134SOD-03 | Director, Accounts Payable OperationsPolicy approver and gate approver | Procurement & Source-to-PayInvoice & Three-Way Match | A. Approved 3 policy items: PR9-POL-200, PR9-POL-201, PR9-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-34A39092SOD-03 | Director, Payment OperationsPolicy approver and gate approver | Procurement & Source-to-PayPayment Interlock | A. Approved 4 policy items: PR10-POL-200, PR10-POL-203, PR10-POL-201, PR10-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-3BC15851SOD-03 | Director, Value AssurancePolicy approver and gate approver | Procurement & Source-to-PaySavings Assurance | A. Approved 2 policy items: PR11-POL-200, PR11-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-C14DF9CCSOD-03 | Director, Demand PlanningPolicy approver and gate approver | Supply ChainDemand Planning | A. Approved 2 policy items: SC1-POL-201, SC1-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-6575E89CSOD-03 | Director, Supply PlanningPolicy approver and gate approver | Supply ChainSupply Planning | A. Approved 3 policy items: SC2-POL-200, SC2-POL-201, SC2-POL-202 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 2026-09-12 | In remediation |
| SOD-03-8CBE549ASOD-03 | VP Integrated Business PlanningPolicy approver and gate approver | Supply ChainSales & Operations Planning | A. Approved 3 policy items: SC3-POL-201, SC3-POL-202, SC3-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 2026-09-13 | Mitigated |
| SOD-03-2B588C68SOD-03 | Director, Inventory ManagementPolicy approver and gate approver | Supply ChainInventory Optimization | A. Approved 4 policy items: SC4-POL-201, SC4-POL-203, SC4-POL-200, SC4-POL-202 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. Target is every clearance carrying two names by the end of the quarter.due 2026-09-14 | In remediation |
| SOD-03-DE964928SOD-03 | Director, LogisticsPolicy approver and gate approver | Supply ChainLogistics & Transportation | A. Approved 3 policy items: SC5-POL-200, SC5-POL-202, SC5-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-2755958FSOD-03 | Director, Fulfillment OperationsPolicy approver and gate approver | Supply ChainWarehouse & Fulfillment | A. Approved 2 policy items: SC6-POL-201, SC6-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-250A83DDSOD-03 | Director, Global TradePolicy approver and gate approver | Supply ChainTrade & Customs | A. Approved 4 policy items: SC7-POL-202, SC7-POL-200, SC7-POL-203, SC7-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 2026-09-17 | In remediation |
| SOD-03-B0C812C4SOD-03 | Director, Supplier CollaborationPolicy approver and gate approver | Supply ChainSupplier Collaboration | A. Approved 3 policy items: SC8-POL-201, SC8-POL-200, SC8-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-F21AC046SOD-03 | Director, Order PromisingPolicy approver and gate approver | Supply ChainOrder Promising | A. Approved 4 policy items: SC9-POL-201, SC9-POL-203, SC9-POL-202, SC9-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-97473127SOD-03 | VP Supply Chain StrategyPolicy approver and gate approver | Supply ChainNetwork Design | A. Approved 2 policy items: SC10-POL-201, SC10-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-B433B520SOD-03 | Director, Supply ResiliencePolicy approver and gate approver | Supply ChainResilience & Risk | A. Approved 3 policy items: SC11-POL-201, SC11-POL-200, SC11-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-C58F4955SOD-03 | VP Engineering OperationsPolicy approver and gate approver | EngineeringPortfolio & Intake | A. Approved 4 policy items: EN1-POL-202, EN1-POL-203, EN1-POL-200, EN1-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-AF1EDC81SOD-03 | Chief ArchitectPolicy approver and gate approver | EngineeringArchitecture & Design | A. Approved 2 policy items: EN2-POL-200, EN2-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-F76062E5SOD-03 | Director, Platform EngineeringPolicy approver and gate approver | EngineeringBuild | A. Approved 4 policy items: EN3-POL-202, EN3-POL-203, EN3-POL-200, EN3-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-FB2F9A61SOD-03 | Director, Engineering QualityPolicy approver and gate approver | EngineeringCode Review & Quality | A. Approved 3 policy items: EN4-POL-200, EN4-POL-201, EN4-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-1EB5A55FSOD-03 | Director, Quality EngineeringPolicy approver and gate approver | EngineeringTest & Assurance | A. Approved 2 policy items: EN5-POL-200, EN5-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. Target is every clearance carrying two names by the end of the quarter.due 2026-09-26 | In remediation |
| SOD-03-7EE9AB92SOD-03 | Director, Release EngineeringPolicy approver and gate approver | EngineeringRelease & Deployment | A. Approved 4 policy items: EN6-POL-201, EN6-POL-203, EN6-POL-200, EN6-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-DBD6883ESOD-03 | Director, Site ReliabilityPolicy approver and gate approver | EngineeringSite Reliability | A. Approved 3 policy items: EN7-POL-201, EN7-POL-200, EN7-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-DA5E8C01SOD-03 | Director, Engineering EffectivenessPolicy approver and gate approver | EngineeringTechnical Debt | A. Approved 2 policy items: EN8-POL-200, EN8-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-FF066B7BSOD-03 | Director, Developer PlatformPolicy approver and gate approver | EngineeringDeveloper Experience | A. Approved 3 policy items: EN9-POL-201, EN9-POL-202, EN9-POL-200 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. Target is every clearance carrying two names by the end of the quarter.due 2026-09-30 | In remediation |
| SOD-03-20B3B8AASOD-03 | Director, Security EngineeringPolicy approver and gate approver | EngineeringSecurity Engineering | A. Approved 3 policy items: EN10-POL-201, EN10-POL-200, EN10-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-C08161D2SOD-03 | Director, Engineering AnalyticsPolicy approver and gate approver | EngineeringEngineering Analytics | A. Approved 4 policy items: EN11-POL-203, EN11-POL-201, EN11-POL-202, EN11-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-05A8EC18SOD-03 | Director, Discovery ResearchPolicy approver and gate approver | Research & DevelopmentDiscovery Research | A. Approved 3 policy items: RD1-POL-202, RD1-POL-201, RD1-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-DC0AB3AASOD-03 | VP InnovationPolicy approver and gate approver | Research & DevelopmentInnovation Portfolio | A. Approved 2 policy items: RD2-POL-200, RD2-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-4FEF447ESOD-03 | Director, Research MethodsPolicy approver and gate approver | Research & DevelopmentExperiment Design | A. Approved 2 policy items: RD3-POL-201, RD3-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-A00A3158SOD-03 | Director, Laboratory OperationsPolicy approver and gate approver | Research & DevelopmentLab Operations | A. Approved 4 policy items: RD4-POL-200, RD4-POL-202, RD4-POL-201, RD4-POL-203 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-933292BASOD-03 | Director, Data SciencePolicy approver and gate approver | Research & DevelopmentData Science & Modeling | A. Approved 4 policy items: RD5-POL-202, RD5-POL-200, RD5-POL-203, RD5-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-1D8C8272SOD-03 | Director, Product DevelopmentPolicy approver and gate approver | Research & DevelopmentPrototype & Pilot | A. Approved 4 policy items: RD6-POL-203, RD6-POL-202, RD6-POL-200, RD6-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-5AE4D718SOD-03 | Director, IP CapturePolicy approver and gate approver | Research & DevelopmentIP Creation & Capture | A. Approved 4 policy items: RD7-POL-203, RD7-POL-200, RD7-POL-202, RD7-POL-201 B. Also approves gates on the lines those policies bind | 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-03-FCA457A8SOD-03 | VP Regulatory SciencePolicy approver and gate approver | Research & DevelopmentRegulatory Science | A. Approved 2 policy items: RD8-POL-200, RD8-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-264F6096SOD-03 | Director, External InnovationPolicy approver and gate approver | Research & DevelopmentExternal Collaboration | A. Approved 3 policy items: RD9-POL-201, RD9-POL-202, RD9-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 2026-09-01 | In remediation |
| SOD-03-8B75ECFASOD-03 | Director, Technology ScoutingPolicy approver and gate approver | Research & DevelopmentTechnology Scouting | A. Approved 4 policy items: RD10-POL-201, RD10-POL-202, RD10-POL-203, RD10-POL-200 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. Target is every clearance carrying two names by the end of the quarter.due 2026-09-02 | In remediation |
| SOD-03-3C862924SOD-03 | Director, R&D AnalyticsPolicy approver and gate approver | Research & DevelopmentPortfolio Analytics | A. Approved 2 policy items: RD11-POL-201, RD11-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-3C936432SOD-03 | VP Financial Planning & AnalysisPolicy approver and gate approver | FinanceFP&A & Planning | A. Approved 4 policy items: FI1-POL-200, FI1-POL-202, FI1-POL-203, FI1-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-463A735CSOD-03 | Director, BudgetingPolicy approver and gate approver | FinanceBudgeting & Forecasting | A. Approved 3 policy items: FI2-POL-200, FI2-POL-202, FI2-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-5C2A0F19SOD-03 | Director, Management ReportingPolicy approver and gate approver | FinanceManagement Reporting | A. Approved 3 policy items: FI3-POL-202, FI3-POL-201, FI3-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-A2390246SOD-03 | Corporate ControllerPolicy approver and gate approver | FinanceRecord-to-Report & Close | A. Approved 3 policy items: FI4-POL-200, FI4-POL-202, FI4-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-8444DFE3SOD-03 | Chief Accounting OfficerPolicy approver and gate approver | FinanceControllership & Policy | A. Approved 4 policy items: FI5-POL-202, FI5-POL-201, FI5-POL-203, FI5-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-E13D31E7SOD-03 | Corporate TreasurerPolicy approver and gate approver | FinanceTreasury & Cash | A. Approved 4 policy items: FI6-POL-201, FI6-POL-202, FI6-POL-203, FI6-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-2A0DF2B6SOD-03 | VP TaxPolicy approver and gate approver | FinanceTax | A. Approved 4 policy items: FI7-POL-201, FI7-POL-202, FI7-POL-200, FI7-POL-203 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-1DCA7D9DSOD-03 | Director, Internal ControlsPolicy approver and gate approver | FinanceInternal Controls & Audit Interlock | A. Approved 3 policy items: FI8-POL-200, FI8-POL-201, FI8-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-FE10E749SOD-03 | VP Investor RelationsPolicy approver and gate approver | FinanceInvestor Relations Support | A. Approved 3 policy items: FI9-POL-201, FI9-POL-200, FI9-POL-202 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 2026-09-12 | In remediation |
| SOD-03-13E2A17CSOD-03 | Director, Profitability AnalyticsPolicy approver and gate approver | FinanceCost & Profitability | A. Approved 4 policy items: FI10-POL-202, FI10-POL-200, FI10-POL-201, FI10-POL-203 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-F3D58763SOD-03 | Director, Finance SystemsPolicy approver and gate approver | FinanceFinance Systems | A. Approved 2 policy items: FI11-POL-200, FI11-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-9EE03151SOD-03 | VP Workforce StrategyPolicy approver and gate approver | Human ResourcesStrategic Workforce Planning | A. Approved 4 policy items: HR1-POL-202, HR1-POL-203, HR1-POL-200, HR1-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-F8748514SOD-03 | VP Talent AcquisitionPolicy approver and gate approver | Human ResourcesTalent Acquisition | A. Approved 4 policy items: HR2-POL-202, HR2-POL-201, HR2-POL-203, HR2-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-E0BF5414SOD-03 | Director, Employee ExperiencePolicy approver and gate approver | Human ResourcesOnboarding | A. Approved 2 policy items: HR3-POL-201, HR3-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-6F949D4BSOD-03 | VP HR Business PartneringPolicy approver and gate approver | Human ResourcesHR Business Partnering | A. Approved 2 policy items: HR4-POL-200, HR4-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-020B7465SOD-03 | Director, Performance & TalentPolicy approver and gate approver | Human ResourcesPerformance Management | A. Approved 4 policy items: HR5-POL-202, HR5-POL-200, HR5-POL-201, HR5-POL-203 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-CD20285FSOD-03 | Director, Learning & CapabilityPolicy approver and gate approver | Human ResourcesLearning & Development | A. Approved 3 policy items: HR6-POL-202, HR6-POL-200, HR6-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 2026-09-20 | In remediation |
| SOD-03-A27505B1SOD-03 | Director, Global MobilityPolicy approver and gate approver | Human ResourcesTalent Mobility | A. Approved 2 policy items: HR7-POL-201, HR7-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-B53864C0SOD-03 | VP Total RewardsPolicy approver and gate approver | Human ResourcesTotal Rewards | A. Approved 4 policy items: HR8-POL-200, HR8-POL-201, HR8-POL-202, HR8-POL-203 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-7E12C85ASOD-03 | Director, Employee RelationsPolicy approver and gate approver | Human ResourcesExit Management | A. Approved 3 policy items: HR9-POL-201, HR9-POL-200, HR9-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-D95A69A8SOD-03 | Director, Culture & EngagementPolicy approver and gate approver | Human ResourcesCulture & Engagement | A. Approved 4 policy items: HR10-POL-201, HR10-POL-202, HR10-POL-203, HR10-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-1F620152SOD-03 | Director, HR TechnologyPolicy approver and gate approver | Human ResourcesHR AI-IT | A. Approved 4 policy items: HR11-POL-203, HR11-POL-201, HR11-POL-200, HR11-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-7B77DB36SOD-03 | Director, Service DeskPolicy approver and gate approver | Information TechnologyService Desk | A. Approved 2 policy items: IT1-POL-201, IT1-POL-200 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. Target is every clearance carrying two names by the end of the quarter.due 2026-09-26 | In remediation |
| SOD-03-E9843B1DSOD-03 | Director, Identity & Access ManagementPolicy approver and gate approver | Information TechnologyIdentity & Access | A. Approved 4 policy items: IT2-POL-203, IT2-POL-201, IT2-POL-202, IT2-POL-200 B. Also approves gates on the lines those policies bind | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-09-27 | Mitigated |
| SOD-03-FD3C2FCCSOD-03 | Director, Workplace TechnologyPolicy approver and gate approver | Information TechnologyEnd-User Compute | A. Approved 3 policy items: IT3-POL-201, IT3-POL-200, IT3-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-059ED366SOD-03 | Director, Cloud InfrastructurePolicy approver and gate approver | Information TechnologyInfrastructure & Cloud | A. Approved 2 policy items: IT4-POL-200, IT4-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-32EB87CFSOD-03 | Director, Network ServicesPolicy approver and gate approver | Information TechnologyNetwork | A. Approved 4 policy items: IT5-POL-201, IT5-POL-203, IT5-POL-202, IT5-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-00517AD5SOD-03 | Director, Application ServicesPolicy approver and gate approver | Information TechnologyApplication Management | A. Approved 4 policy items: IT6-POL-202, IT6-POL-200, IT6-POL-203, IT6-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-1CC4522BSOD-03 | Director, Security OperationsPolicy approver and gate approver | Information TechnologyCybersecurity Operations | A. Approved 2 policy items: IT7-POL-200, IT7-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-84AA4AB5SOD-03 | Director, Data PlatformPolicy approver and gate approver | Information TechnologyData & Integration Platform | A. Approved 4 policy items: IT8-POL-201, IT8-POL-200, IT8-POL-203, IT8-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-3024DF2FSOD-03 | Director, IT Asset ManagementPolicy approver and gate approver | Information TechnologyAsset & License | A. Approved 4 policy items: IT9-POL-200, IT9-POL-202, IT9-POL-203, IT9-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-91080704SOD-03 | Director, Change ManagementPolicy approver and gate approver | Information TechnologyChange & Release | A. Approved 3 policy items: IT10-POL-200, IT10-POL-201, IT10-POL-202 B. Also approves gates on the lines those policies bind | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-08-26 | 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.
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.