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
34 matching, showing up to 120
| Reference | Holder | Where | Both sides | Owner and fix | State |
|---|---|---|---|---|---|
| SOD-01-3B5CC111SOD-01 | M. ReyesItem owner and raiser | SalesProposal assembly — Halstead expansion | A. Raised SLS-4823 — Proposal assembly — Halstead expansion B. Holds the decision on SLS-4823 in the same queue | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-08-26 | Mitigated |
| SOD-01-3E5CC5CASOD-01 | Sales CoSItem owner and raiser | SalesCRM reconciliation — EMEA mid-market | A. Raised SLS-4826 — CRM reconciliation — EMEA mid-market B. Holds the decision on SLS-4826 in the same queue | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-08-27 | Mitigated |
| SOD-01-E185F1C2SOD-01 | Legal CoSItem owner and raiser | LegalNDA batch draft — supplier onboarding | A. Raised LGL-1181 — NDA batch draft — supplier onboarding B. Holds the decision on LGL-1181 in the same queue | 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-01-F44B2834SOD-01 | Supply Chain CoSItem owner and raiser | Supply ChainCarrier allocation — week 34 outbound | A. Raised SCM-3323 — Carrier allocation — week 34 outbound B. Holds the decision on SCM-3323 in the same queue | 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 | Mitigated |
| 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-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-02-64FD34A1SOD-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-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-02-754CF120SOD-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-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-02-90D1878FSOD-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-02-6DAD8B88SOD-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-02-8D70B4C5SOD-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-02-2CA55538SOD-02 | Director, IT Financial ManagementStation owner and gate approver | Information TechnologyIT Financial Management | A. Owns 3 stations on line IT11C B. Approves the same 3 gates: CIO ratify, Owner review, CIO review | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-09-03 | Mitigated |
| SOD-02-58BA5371SOD-02 | Director, Workplace ServicesStation owner and gate approver | AdministrationFacilities & Workplace | A. Owns 2 stations on line AD1C B. Approves the same 2 gates: Approve, Ratify | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-09-04 | Mitigated |
| SOD-02-A9A3CC6BSOD-02 | Head of Service AnalyticsStation owner and gate approver | Customer ServiceService Analytics | A. Owns 3 stations on line CS11C B. Approves the same 3 gates: Ratify, Ratify, 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 | Mitigated |
| SOD-02-3EF372E3SOD-02 | Head of Service CatalogStation owner and gate approver | AI GBS & Global Business ServicesService Catalog & Intake | A. Owns 2 stations on line GB5C B. Approves the same 2 gates: Route or refuse, Approve | 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 | Mitigated |
| 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-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-03-13103B42SOD-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-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-03-668990DESOD-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-03-8CBE549ASOD-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-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-03-69ADB134SOD-03 | Head of Customer ExperiencePolicy approver and gate approver | Customer ServiceVoice of Customer | A. Approved 3 policy items: CS8-POL-200, CS8-POL-202, CS8-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 2026-09-14 | Mitigated |
| SOD-03-2220D116SOD-03 | Director, Service QualityPolicy approver and gate approver | Customer ServiceQuality & Coaching | A. Approved 4 policy items: CS9-POL-203, CS9-POL-202, CS9-POL-200, CS9-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 2026-09-15 | Mitigated |
| SOD-04-C587AE39SOD-04 | Director, Sales EnablementSub-function owner and rating attester | SalesSales Enablement | A. Owns 9 agents running at autonomy level 75 B. Stands behind the A estate rating that grades those same agents | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. Target is every clearance carrying two names by the end of the quarter.due 2026-09-30 | Mitigated |
| SOD-04-329397EFSOD-04 | VP Demand GenerationSub-function owner and rating attester | MarketingDemand Generation | A. Owns 9 agents running at autonomy level 80 B. Stands behind the A estate rating that grades those same agents | 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-04-C1E5909ASOD-04 | Director, Revenue DataSub-function owner and rating attester | Revenue OperationsCRM Data Stewardship | A. Owns 8 agents running at autonomy level 83 B. Stands behind the A estate rating that grades those same agents | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-08-30 | Mitigated |
| SOD-04-A0A91D4ASOD-04 | VP Talent AcquisitionSub-function owner and rating attester | Human ResourcesTalent Acquisition | A. Owns 12 agents running at autonomy level 70 B. Stands behind the A estate rating that grades those same agents | 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-04-3715F7BFSOD-04 | Director, Workplace TechnologySub-function owner and rating attester | Information TechnologyEnd-User Compute | A. Owns 8 agents running at autonomy level 74 B. Stands behind the A estate rating that grades those same agents | 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-04-9969630DSOD-04 | Director, IT Financial ManagementSub-function owner and rating attester | Information TechnologyIT Financial Management | A. Owns 8 agents running at autonomy level 66 B. Stands behind the A estate rating that grades those same agents | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-08-30 | Mitigated |
| SOD-04-03EC3239SOD-04 | Director, Fleet & AssetsSub-function owner and rating attester | AdministrationFleet & Assets | A. Owns 9 agents running at autonomy level 78 B. Stands behind the A estate rating that grades those same agents | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. Target is every clearance carrying two names by the end of the quarter.due 2026-09-02 | Mitigated |
| SOD-04-9BE269F2SOD-04 | Tower Lead, Hire-to-RetireSub-function owner and rating attester | AI GBS & Global Business ServicesH2R Control Tower | A. Owns 12 agents running at autonomy level 78 B. Stands behind the A estate rating that grades those same agents | 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 |
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.