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Off-shoring / Outsourcing
                             Assurance



                                                           Promoting
Techserv Consulting            Confidential & Private
                                                                       1
                                                        Systems Integrity
OUTSOURCING / OFF-SHORING CONTROLS




                         Use of service providers doesn’t
                      reduce the Responsibility of corporate
                       executives from maintaining effective
                                 internal controls
                                 - Public Company Accounting Oversight Board




                                                                                  Promoting
Techserv Consulting                   Confidential & Private
                                                                                              2
                                                                               Systems Integrity
THIS IS MEANT FOR THOSE WHO HAVE CONCERNS ON THE
   FOLLOWING                  …………
                      DO YOU WISH TO OUTSOURCE / OFFSHORE IT SERVICES?

                      ARE YOU NOT SURE ABOUT SELECTING THE RIGHT IT SUPPLIER?

                      DO YOU FEEL THE NEED TO CONSIDER EXTERNAL DUE DILIGENCE COMPETENCE?

                      WOULD YOU LIKE TO BE INDEPENDENT IN SUPPLIER SELECTION?

                      ARE YOU NOT SURE ABOUT LOCAL REALITIES AND SUPPLIER FACTS?

                      ARE YOU NOT ABLE TO ASSURE YOURSELF THAT SUPPLIER BILLING IS ACCURATE?

                      HAVE YOU REGULARLY OBSERVED THAT SLAs ARE NOT COMPLIED WITH?

                      ARE YOU NOT SURE THAT SUPPLIER IS FOLLOWING THE PROCESSES AS AGREED?

                      ARE YOUR DELIVERABLES BECOME UNPREDICTABLE?

                      DO YOU FIND SUPPLIER’S PRODUCT QUALITY IS NOT ACCEPTABLE?

                      ARE YOU FEELING MISALIGNED WITH THE SUPPLIER?

                      ARE YOU NOT SURE THAT IT / IS SECURITY WILL NOT BE COMPROMISED?


                                                                                           Promoting
Techserv Consulting                                Confidential & Private
                                                                                                       3
                                                                                        Systems Integrity
Off-shoring / Outsourcing Risks Vs. Controls
   Wrong selection of       Lack of unity
                                                 Dishonor of             Resource / Billing      Failure to
      of Supplier /           Of minds.                                                       realize benefits,    Risks
      processes /           Expectation          Obligations,              Inaccuracies,      Reverse flow of
     Applications?                          Information security?            Leakages?          knowledge?
                             Alignment?




                                                                                                                   Phases




             Strategies       Transition             Execution               Execution             Programme
                 &           (Knowledge               (Steady                (Value add              Closure
              Planning        Transfer)                State)                  State)



     Strategy             Transition          Continuous                 Continuous             Continuous        Control
   Due-Diligence          Advisory            Assurance                  Assurance              Assurance         Measures



    Strategic              Process            Cultural &                   Value                  Smooth          Desired
    Alignment             Alignment          Performance                 Alignment                Reverse         Results
                                              Alignment                                          Transition

                                                                                                              Promoting
Techserv Consulting                             Confidential & Private
                                                                                                                          4
                                                                                                           Systems Integrity
The Need for Independent Outsourcing Oversight




                                               Security                  Execution
                                              Assurance                  Assurance
                                   Start-up                                          Relationship
                                  Assurance                                           Assurance




                       Value / Cost                                                          Compliance
                        Assurance                                                            Assurance


          Outsourcing organizations require a structured, independent and competent
          assurance throughout the outsourcing / off-shoring relationships. This would help the
          organization to have checks and balances to realize the objectives.

          We have the competence to provide assurance services to the organizations to ensure
          that the outsourcing relationships realize the anticipated benefits.


                                                                                                             Promoting
Techserv Consulting                             Confidential & Private
                                                                                                                         5
                                                                                                          Systems Integrity
The focus areas of Outsourcing Assurance

                                                                                                 Outsourcing Assurance is a management
                                                                                                 process to provide a independent comfort to
                                                                                                 management that Outsourcing engagement
                                                                                                 processes are effective and efficient enough to
                                                                                                 provide the desired results envisaged at the
                                                                                                 beginning of the outsourcing engagement. Also,
                                       IC                                                        to provide identified material weaknesses in the
                                    EG NT        AL VAL
                                  AT E             IG UE                                         outsourcing processes either at Outsourced
                                TR GNM
                               S I
                                                     NM
                                                        EN                                       organization or at supplier end.
                                AL                         T

                                                                                                 This assurance function should be established
                                      Outsourcing                                                at strategic checkpoints to provide the required
                      PER IGNME




                                                                   NT
                                                         A LI G U R E


                                       Alignment                                                 alignment in the following focus areas:
                        AL
                         FOR




                                                               NME
                                                                T
                                                           CUL
                             MA N T




                                       www.itgi.org                                                    Strategic Alignment
                                 N




                                                                                                       Value alignment
                                 CE




                                                                                                       Performance alignment
                                       PROCESS
                                      ALIGNMENT                                                        Culture alignment
                                                                                                       Product alignment




                                                                                                                                            Promoting
Techserv Consulting                                                     Confidential & Private
                                                                                                                                                        6
                                                                                                                                         Systems Integrity
Why Outsourcing Assurance focus on these areas?



                                              Focuses on ensuring the linkage of business and outsourcing plans;
                      Strategic alignment     on defining, maintaining and validating the outsourcing value proposition;
                                              and on aligning outsourcing operations with enterprise operations

                                              Is about executing the value proposition throughout the outsourcing cycle,
                      Value alignment         ensuring that supplier delivers the benefits against the outsourcing strategy,
                                              concentrating on optimising costs and proving the intrinsic value of outsourcing



                      Culture alignment       Focuses on bridging the cultural gaps between two organization



                                              Focuses on ensuring required process infrastructure is established and
                                              implemented and institutionalized to have transparency in outsourced
                      Process alignment       processes. Ensure that these processes are improved continually and aligned
                                              to outsourcing objectives


                                              Tracks and monitors strategy implementation, project completion, resource
                      Performance alignment   usage, process performance and service delivery, using, for example,
                                              scorecards that translate strategy into action to achieve goals measurable
                                              beyond conventional accounting


                                                                                                                      Promoting
Techserv Consulting                             Confidential & Private
                                                                                                                                  7
                                                                                                                   Systems Integrity
Outsourcing Assurance aims




                         Conformance
                          • Adhering to Laws, Regulations, Legislation,
                            Policies and Procedures, audit requirements,
                            etc.

                         Performance                                                  Performance
                           • Improving Performance Score card,
                             Outsourcing efficiency and effectiveness,
                             growth, etc.                                                           Conformance




                      Outsourcing Assurance aims to balance conformance and performance goals




                                                                                                                     Promoting
Techserv Consulting                                          Confidential & Private
                                                                                                                                 8
                                                                                                                  Systems Integrity
Outsourcing Governance Stakeholders


                      Board and executive       Set direction for outsourcing, monitor results and insist on
                                                corrective measures

                                                Defines business requirements for outsourcing and ensures
                      Business management       that value is delivered and risks are managed


                      Supplier management       Monitors outsourcing services as required by the Business
                                                Management


                                                Provides independent assurance services to demonstrate
                      Assurance services        that outsourcing delivers what is needed



                      Outsourcing management    Delivers and improves outsourcing services as required by
                                                the Client Management


                      Risk and compliance       Measures compliance with policies and focuses on alerts to
                                                new risks


                          Supplier             Service Buyer                      Independent Assurance
                                                                                                             Promoting
Techserv Consulting                            Confidential & Private
                                                                                                                         9
                                                                                                          Systems Integrity
Outsourcing Assurance Framework


                      Enterprise Drivers            PERFORMANCE                               CONFORMANCE
                                                     Business Goals                           Acts & Regulations




     A                Outsourcing Drivers                Scorecard
                                                                                              Sarbanes-Oxley Act,                 A
                                                                                              COBIT,CMMI,ISO
     S                                                                                            27001 etc.                      S
     S                                                                                                                            S
     U                                                                                                                            U
     R                Outsourcing Governance
                                                                                                                                  R
                                                                                 COBIT
     A                                                                                                                            A
     N                                                                                                                            N
     C                                                                                                                            C
     E                Best Practice Standards
                                                     ISO                           ISO
                                                                                                          CMMI
                                                                                                                                  E
                                                  9001:2008                       27001




                       Processes and Procedures   Governance                     Functional             Operational
                                                   Processes                     Processes               Processes



                                                                                                                         Promoting
Techserv Consulting                                     Confidential & Private
                                                                                                                                     10
                                                                                                                      Systems Integrity
Alignment Agents

                                                                                       Program Management

                                                                                           •




                                                                   A




                                                                                                                                                            A
                                                                                               Process Design




                                                               l




                                                                                                                                                                    l
                                                                                           •

                                                           i
                                                                                               Process Implementation




                                                                                                                                                                        i
                                                                                                                                                            V
                                                       g




                                                                                                                                                                                g
                                                               V




                                                                                                                                                                    a
                                                   n                                       •




                                                                                                                                                                                    n
                                                                                               Delivery Management

                                                           a
                                       m




                                                                                                                                                                                            m
                                                                                                                                                                        l
                                                       l




                                                                                                                                                                                u
                                   e


                                                                                           •




                                                                                                                                                                                                    e
                                                                                               SLA Management
                                                   u




                                                                                                                                                                                    e
                               n




                                                                                                                                                                                                            n
                                           e
                           t




                                                                                                                                                                                                                t
                                                                                                       P                    P
                                                                                                   R                            R
                      Program Management                                                       O                                    O                           Client Management
                                                                                           D                                            C
                      •                                                                U                                                    E
                          Contract Administration                                  T                                                            S           •       Contract Administration
                      •                                                                             Assurance                                       S
                          Program Oversight                                                                                                                 •       Program Planning
                                                                                                   (Alignment Agents)
                      •   SLA Management                                                                                                                    •       Program Oversight
                      •   Program Oversight                                                                                                                 •       Escalation Resolution

                                                                                               PERFORMANCE
                                                                                                                                                                                                        S
                                       S                                                                                                                                                        t
                               A               t                                           Supplier Management                                                                                              A
                                                   r                                                                                                                                    r               l
                                   l                                                                                                                                            a
                                           i           a                                                                                                                                            i
                                                                                                                                                                            t
                                                   g       t                           •       Outsourcing Strategies                                                   e
                                                                                                                                                                                            g
                                                       n       e                                                                                                                    n
                                                                   g                   •       Outsourcing Oversight                                                g           m
                                                           m                                                                                                I
                                                               e           I                                                                                            e
                                                                   n           c       •       Supplier Selection                                       c           n
                                                                       t                                                                                        t
                                                                                       •       Program termination

                                                                                                                                                                                                                       Promoting
Techserv Consulting                                                                                Confidential & Private
                                                                                                                                                                                                                                   11
                                                                                                                                                                                                                    Systems Integrity
Assurance Scope (Strategy & Planning)

                                                                                            Deliverables
                                                                                            Report on Strategies
                  Strategy &                  Transition
                                                                                            Due Diligence Reports
                   Planning
                                                                                            Supplier selection process review report
                               IT Processes                                                 Information Security Assessment report
                                                                                            Systems & Processes assessment Report
                                                                                            Contract Review Report


              Execution                       Program                               Strategy & Planning
                                              Closure
                                                                                    Strategy reviews
                                                                                    Planning reviews
                                                                                    Supplier Selection reviews
                                                                                    Supplier infrastructure due diligence
                      Outcome                                                       Suppliers Human Resources due diligence
                      Right Pricing is established
                                                                                    Suppliers Process infrastructure due diligence
                      Strategy and Planning verified
                      Suppliers’ claims validated                                   Supplier readiness due diligence
                      Risks towards security assessed                               Contract negotiation / re-negotiation (Pricing)
                      Human resources claims assessed
                      Outsourcing (Supplier) readiness assessed                     Information Security and Privacy assessment
                      Outsourcing (Customer) readiness assessed                     Effort estimation review


                                                                                                                              Promoting
Techserv Consulting                                        Confidential & Private
                                                                                                                                          12
                                                                                                                           Systems Integrity
Assurance Scope (Transition)

                                                                                                Deliverables
               Strategy &
                                                Transition                                      Review Reports (Processes in transition)
                Planning
                                                                                                Process documentation (if required)
                                IT Processes                                                    Review report on Knowledge transfer
                                                                                                Establish On-site Oversight mechanisms
                                                                                                Review of Staffing
                                                                                                Audit reports (Transition Phase

              Execution                         Program
                                                Closure                               Transition
                                                                                      Transition Planning review
                                                                                      Transition Schedule review
                                                                                      Program staffing review
                            Outcome
                            Effective transition strategy                             Knowledge transfer execution audit
                            Efficient transition strategy                             Pilot project execution review
                            Process infrastructure readiness
                                                                                      Program & Project Planning Process definition
                            Program transition health status
                            Pilot project validation                                  Program & Project execution Process definition
                            Supplier readiness against the plan                       Quality Assurance Process definition
                            Risk assessment and mitigation
                                                                                      Quality Control process definition
                                                                                      Information Security process definition
                                                                                                                               Promoting
Techserv Consulting                                          Confidential & Private
                                                                                                                                           13
                                                                                                                            Systems Integrity
Assurance Scope (Execution)


              Strategy &                   Transition
                                                                                              Deliverables
                Planning
                                                                                              Process advisory
                            Assurance                                                         Process Audit reports
                                                                                              Information Security audit reports
                                                                                              Billing verification report


                                           Program
          Execution
                                           Closure
                                                                                 Execution

                                                                                 Periodic Audit of Contractual obligations
                                                                                 Periodic Audit of Information Security processes
                      Outcome
                      Alignment of execution processes                           Periodic Audit of process implementation
                      Alignment of info. Security requirements                   Periodic Audit of Service Level Agreements
                      Independent Program status                                 Periodic Audit of deviations, escalations
                      Process improvements
                      Contractual obligations by supplier                        Periodic Audit of Supplier’s infrastructure
                      Risk identification & Mitigation                           Periodic Audit of Billing Account
                      Accurate billing as per contract



                                                                                                                           Promoting
Techserv Consulting                                     Confidential & Private
                                                                                                                                       14
                                                                                                                        Systems Integrity
Assurance Scope (Program Closure)


             Strategy &                     Transition
              Planning
                                                                                                  Deliverables
                            IT Processes                                                          Review Reports
                                                                                                  Validation Reports
                                                                                                  Audit report


               Execution                    Program
                                            Closure
                                                                              Program Closure


                                                                                  Reverse Transition Planning
                      Outcome                                                     Reverse Transitioning
                      Smooth reverse transition
                      Compliance to regulations, laws etc.,                       Contract, Regulatory compliance
                      Effective reverse knowledge transfer                        Program sign-offs
                      All assets are returned                                     Program closure




                                                                                                                          Promoting
Techserv Consulting                                      Confidential & Private
                                                                                                                                      15
                                                                                                                       Systems Integrity
Any Queries ?




                                                                Please Contact:

                                                               ARUL NAMBI

                                                    aruln@techservconsult.com

                                                               +91 9892504538

                                                       www.techservconsult.com


                                                                                     Promoting
Techserv Consulting                   Confidential & Private
                                                                                                 16
                                                                                  Systems Integrity

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IT OUTSOURCING ASSURANCE

  • 1. Off-shoring / Outsourcing Assurance Promoting Techserv Consulting Confidential & Private 1 Systems Integrity
  • 2. OUTSOURCING / OFF-SHORING CONTROLS Use of service providers doesn’t reduce the Responsibility of corporate executives from maintaining effective internal controls - Public Company Accounting Oversight Board Promoting Techserv Consulting Confidential & Private 2 Systems Integrity
  • 3. THIS IS MEANT FOR THOSE WHO HAVE CONCERNS ON THE FOLLOWING ………… DO YOU WISH TO OUTSOURCE / OFFSHORE IT SERVICES? ARE YOU NOT SURE ABOUT SELECTING THE RIGHT IT SUPPLIER? DO YOU FEEL THE NEED TO CONSIDER EXTERNAL DUE DILIGENCE COMPETENCE? WOULD YOU LIKE TO BE INDEPENDENT IN SUPPLIER SELECTION? ARE YOU NOT SURE ABOUT LOCAL REALITIES AND SUPPLIER FACTS? ARE YOU NOT ABLE TO ASSURE YOURSELF THAT SUPPLIER BILLING IS ACCURATE? HAVE YOU REGULARLY OBSERVED THAT SLAs ARE NOT COMPLIED WITH? ARE YOU NOT SURE THAT SUPPLIER IS FOLLOWING THE PROCESSES AS AGREED? ARE YOUR DELIVERABLES BECOME UNPREDICTABLE? DO YOU FIND SUPPLIER’S PRODUCT QUALITY IS NOT ACCEPTABLE? ARE YOU FEELING MISALIGNED WITH THE SUPPLIER? ARE YOU NOT SURE THAT IT / IS SECURITY WILL NOT BE COMPROMISED? Promoting Techserv Consulting Confidential & Private 3 Systems Integrity
  • 4. Off-shoring / Outsourcing Risks Vs. Controls Wrong selection of Lack of unity Dishonor of Resource / Billing Failure to of Supplier / Of minds. realize benefits, Risks processes / Expectation Obligations, Inaccuracies, Reverse flow of Applications? Information security? Leakages? knowledge? Alignment? Phases Strategies Transition Execution Execution Programme & (Knowledge (Steady (Value add Closure Planning Transfer) State) State) Strategy Transition Continuous Continuous Continuous Control Due-Diligence Advisory Assurance Assurance Assurance Measures Strategic Process Cultural & Value Smooth Desired Alignment Alignment Performance Alignment Reverse Results Alignment Transition Promoting Techserv Consulting Confidential & Private 4 Systems Integrity
  • 5. The Need for Independent Outsourcing Oversight Security Execution Assurance Assurance Start-up Relationship Assurance Assurance Value / Cost Compliance Assurance Assurance Outsourcing organizations require a structured, independent and competent assurance throughout the outsourcing / off-shoring relationships. This would help the organization to have checks and balances to realize the objectives. We have the competence to provide assurance services to the organizations to ensure that the outsourcing relationships realize the anticipated benefits. Promoting Techserv Consulting Confidential & Private 5 Systems Integrity
  • 6. The focus areas of Outsourcing Assurance Outsourcing Assurance is a management process to provide a independent comfort to management that Outsourcing engagement processes are effective and efficient enough to provide the desired results envisaged at the beginning of the outsourcing engagement. Also, IC to provide identified material weaknesses in the EG NT AL VAL AT E IG UE outsourcing processes either at Outsourced TR GNM S I NM EN organization or at supplier end. AL T This assurance function should be established Outsourcing at strategic checkpoints to provide the required PER IGNME NT A LI G U R E Alignment alignment in the following focus areas: AL FOR NME T CUL MA N T www.itgi.org Strategic Alignment N Value alignment CE Performance alignment PROCESS ALIGNMENT Culture alignment Product alignment Promoting Techserv Consulting Confidential & Private 6 Systems Integrity
  • 7. Why Outsourcing Assurance focus on these areas? Focuses on ensuring the linkage of business and outsourcing plans; Strategic alignment on defining, maintaining and validating the outsourcing value proposition; and on aligning outsourcing operations with enterprise operations Is about executing the value proposition throughout the outsourcing cycle, Value alignment ensuring that supplier delivers the benefits against the outsourcing strategy, concentrating on optimising costs and proving the intrinsic value of outsourcing Culture alignment Focuses on bridging the cultural gaps between two organization Focuses on ensuring required process infrastructure is established and implemented and institutionalized to have transparency in outsourced Process alignment processes. Ensure that these processes are improved continually and aligned to outsourcing objectives Tracks and monitors strategy implementation, project completion, resource Performance alignment usage, process performance and service delivery, using, for example, scorecards that translate strategy into action to achieve goals measurable beyond conventional accounting Promoting Techserv Consulting Confidential & Private 7 Systems Integrity
  • 8. Outsourcing Assurance aims Conformance • Adhering to Laws, Regulations, Legislation, Policies and Procedures, audit requirements, etc. Performance Performance • Improving Performance Score card, Outsourcing efficiency and effectiveness, growth, etc. Conformance Outsourcing Assurance aims to balance conformance and performance goals Promoting Techserv Consulting Confidential & Private 8 Systems Integrity
  • 9. Outsourcing Governance Stakeholders Board and executive Set direction for outsourcing, monitor results and insist on corrective measures Defines business requirements for outsourcing and ensures Business management that value is delivered and risks are managed Supplier management Monitors outsourcing services as required by the Business Management Provides independent assurance services to demonstrate Assurance services that outsourcing delivers what is needed Outsourcing management Delivers and improves outsourcing services as required by the Client Management Risk and compliance Measures compliance with policies and focuses on alerts to new risks Supplier Service Buyer Independent Assurance Promoting Techserv Consulting Confidential & Private 9 Systems Integrity
  • 10. Outsourcing Assurance Framework Enterprise Drivers PERFORMANCE CONFORMANCE Business Goals Acts & Regulations A Outsourcing Drivers Scorecard Sarbanes-Oxley Act, A COBIT,CMMI,ISO S 27001 etc. S S S U U R Outsourcing Governance R COBIT A A N N C C E Best Practice Standards ISO ISO CMMI E 9001:2008 27001 Processes and Procedures Governance Functional Operational Processes Processes Processes Promoting Techserv Consulting Confidential & Private 10 Systems Integrity
  • 11. Alignment Agents Program Management • A A Process Design l l • i Process Implementation i V g g V a n • n Delivery Management a m m l l u e • e SLA Management u e n n e t t P P R R Program Management O O Client Management D C • U E Contract Administration T S • Contract Administration • Assurance S Program Oversight • Program Planning (Alignment Agents) • SLA Management • Program Oversight • Program Oversight • Escalation Resolution PERFORMANCE S S t A t Supplier Management A r r l l a i a i t g t • Outsourcing Strategies e g n e n g • Outsourcing Oversight g m m I e I e n c • Supplier Selection c n t t • Program termination Promoting Techserv Consulting Confidential & Private 11 Systems Integrity
  • 12. Assurance Scope (Strategy & Planning) Deliverables Report on Strategies Strategy & Transition Due Diligence Reports Planning Supplier selection process review report IT Processes Information Security Assessment report Systems & Processes assessment Report Contract Review Report Execution Program Strategy & Planning Closure Strategy reviews Planning reviews Supplier Selection reviews Supplier infrastructure due diligence Outcome Suppliers Human Resources due diligence Right Pricing is established Suppliers Process infrastructure due diligence Strategy and Planning verified Suppliers’ claims validated Supplier readiness due diligence Risks towards security assessed Contract negotiation / re-negotiation (Pricing) Human resources claims assessed Outsourcing (Supplier) readiness assessed Information Security and Privacy assessment Outsourcing (Customer) readiness assessed Effort estimation review Promoting Techserv Consulting Confidential & Private 12 Systems Integrity
  • 13. Assurance Scope (Transition) Deliverables Strategy & Transition Review Reports (Processes in transition) Planning Process documentation (if required) IT Processes Review report on Knowledge transfer Establish On-site Oversight mechanisms Review of Staffing Audit reports (Transition Phase Execution Program Closure Transition Transition Planning review Transition Schedule review Program staffing review Outcome Effective transition strategy Knowledge transfer execution audit Efficient transition strategy Pilot project execution review Process infrastructure readiness Program & Project Planning Process definition Program transition health status Pilot project validation Program & Project execution Process definition Supplier readiness against the plan Quality Assurance Process definition Risk assessment and mitigation Quality Control process definition Information Security process definition Promoting Techserv Consulting Confidential & Private 13 Systems Integrity
  • 14. Assurance Scope (Execution) Strategy & Transition Deliverables Planning Process advisory Assurance Process Audit reports Information Security audit reports Billing verification report Program Execution Closure Execution Periodic Audit of Contractual obligations Periodic Audit of Information Security processes Outcome Alignment of execution processes Periodic Audit of process implementation Alignment of info. Security requirements Periodic Audit of Service Level Agreements Independent Program status Periodic Audit of deviations, escalations Process improvements Contractual obligations by supplier Periodic Audit of Supplier’s infrastructure Risk identification & Mitigation Periodic Audit of Billing Account Accurate billing as per contract Promoting Techserv Consulting Confidential & Private 14 Systems Integrity
  • 15. Assurance Scope (Program Closure) Strategy & Transition Planning Deliverables IT Processes Review Reports Validation Reports Audit report Execution Program Closure Program Closure Reverse Transition Planning Outcome Reverse Transitioning Smooth reverse transition Compliance to regulations, laws etc., Contract, Regulatory compliance Effective reverse knowledge transfer Program sign-offs All assets are returned Program closure Promoting Techserv Consulting Confidential & Private 15 Systems Integrity
  • 16. Any Queries ? Please Contact: ARUL NAMBI aruln@techservconsult.com +91 9892504538 www.techservconsult.com Promoting Techserv Consulting Confidential & Private 16 Systems Integrity