Projects:French Fiscal/Openbravo Compliance Management System

Contents 1 Openbravo Compliance Management System 1.1 Context 1.2 Roles and Responsabilities 1.2.1 Openbravo Product Software Engeering team 1.2.2 Openbravo Services team 1.3 Objectives and implementation of the CMS 1.4 Legal and regulatory watch 1.5 Establishment of compliance checks 1.6 Design and development of the collection system 1.7 Control of subcontractors 1.8 Identification and traceability of distribution 1.9 Communication with customers 1.10 Use of the LNE mark - Cash Register System 1.11 Evaluation and improvement of MSC performance 1.12 Anomaly handling 1.13 Records management

Openbravo Compliance Management System

Openbravo has implemented, evaluated and will update if required, a Compliance Management System designed to ensure that each cash register system distributed or updated distributed, meet the LNE standard requirements v 1.6.

Context

This section is intended to determine and register the internal and external issues as well as risks associated with the compliance of the cash register system distributed.

For any risk identified, the corresponding Action and Owner have also be stablished in order to monitor, reduce and eliminate the risk, if possible.

For additional information, please review the document: Openbravo Risk Analysis v 6.0.

Roles and Responsabilities

Openbravo is a software solution vendor that offers a global POS and retail management software with the aim of helping midsize and large business to successfully manage their retail operations.

“Openbravo Commerce Suite” is the Openbravo’s commercial offering for the Retail Industry. This suite offers a unique store solution or cash register system, composed by a set of modules that once installed on top of Openbravo, deliver the retail functionality provided by Openbravo and the technology to extend and create new retail functionality to adapt Openbravo as required.

Besides that, Openbravo Commerce Suite is backed by a complete back office functionality that is the Openbravo Business Suite. The Openbravo business suite offers a comprehensive business management solution with built-in ERP capabilities.

Openbravo Product Software Engeering team

The Openbravo design and development proccess is intended to establish, implement and maintain the subsequent provision of the Openbravo product's suites.

The Openbravo Product SW Engineering team is responsible of all the task related to the design and development process, and it is composed by below list of teams:

• Product Management
• Development
  • Platform
  • Retail
  • Functional
• Q&A
• Release management

Those teams include below listed roles and responsibilities:

• a VP Product SW Engineer in charge of:
  • develop Product Vision & Strategy into Roadmap priorities
  • present Product Strategy & Roadmap to third parties
  • delivering Product roadmap on time with quality
  • delivering Bug resolution according to Product SLAs
  • act as domain expert for roadmap definition tasks and help secure client success

• Product Managers in charge of:
  • defining in the corresponding Functional Specification the features or requirements included in the product roadmap, as it basis for its implementation
  • ensuring that the features developed work as required
  • act as domain expert for the features delivered and help secure client success
    • Besides the above, the Functional Product Manager is the one in charge of :
      • ensuring that the compliance management system complies with Chapter III, in collaboration with the "Functional Team Lead" and under "VP Product SW Engineer" supervision.
      • providing training/information sessions for the employees on the new features implemented
      • providing training/information sessions for the employees in order to ensure that they are aware of the compliance requirements that concern them, in collaboration with the Functional Team Lead and Functional Senior Engineer
      • identifying and managing the risks associated with compliance in relation to third parties such as suppliers and subcontractors, in collaboration with Product Team Lead and the Openbravo Legal Department.
      • supervising outsourcing conditions in order to ensure that they take into account the compliance requirements defined in this standard, with the collaboration of the Functional Teal Lead and Openbravo Legal department.

• Engineer Team Leads in charge of:
  • analyzing any technical requirement or new functionality included in the product roadmap.
  • designing in the corresponding Technical Specification the features or requirements included in the product roadmap, as it basis for its implementation
  • estimating product roadmap features, based on the functional specifications provided by the corresponding Product Manager.
  • planning the task to be assigned to each team member within each development release cycle
  • taking "product owner" role of the features to be developed by his/her team
  • taking team "management" tasks
  • ensuring that all features included in the product roadmap are delivered and with quality, as planned on a quarterly basis
  • developing complex programs using technical system capabilities, non-standard routines and software tools
    • Besides the above, the Functional Team Lead is the one in charge of:
      • analyzing the technical requirements defined in Chapter IV, in collaboration with other Team Leads (Platform and Retail), and the Functional Senior Engineer.
      • breaking the technical requirements defined in Chapter IV down into functional specifications that can be implemented, in collaboration with the Functional Senior Engineer, the Functional Product Manager; and under the supervision of other Team Leads (Platform and Retail) and VP Product SW Engineer
      • defining compliance performance indicators, in collaboration with the Functional Product Manager, and under the supervision of the VP Product SW Engineer
      • checking and measuring these indicators, in collaboration with other Team Leads, the Functional Product Manager, and under the supervision of the VP Product Software Engineer.
      • analyzing the results to identify whether corrective actions are necessary, in collaboration with other Team Leads, the Functional Product Manager, and under the supervision of the VP Product Software Engineer.

• Senior Engineer in charge of:
  • coding complex problems or features
  • analyzing and designing application systems encompassing development and modification
  • translating application requirements into practical system designs for input handling, processing and output preparation.
  • documenting detailed systems designs specifications and/or modification requirements for inclusion in system manuals.
  • coordinating the activity of less experienced programmers

• Engineers in charge of:
  • developing professional working on projects or module of projects
  • coding and debugging new software products by performing basic systems analysis work. This role requires close supervision.

• QA Team Lead in charge of:
  • estimating QA cycle for the product roadmap features, based on the specifications provided by the corresponding Product Manager.
  • planning the tasks to be assigned to each team member within each development release cycle
  • taking role of "product owner" of the features to be developed by the team
  • taking team "management" tasks
  • ensuring that all features included in the product roadmap are delivered and with quality, as planned on a quarterly basis

• QA Senior Engineer in charge of:
  • testing assessment (manual and automated) of complex features
  • translating complex application requirements into practical testcases.
  • documenting any discrepancy in planned systems designs specifications when packaged in a release
  • coordinating the activity of less experienced engineers

• QA Engineers in charge of:
  • testing assessment (manual and automated) of general features
  • translating general application requirements into practical testcases.
  • documenting any discrepancy in the planned requirements when packaged in a release

• RM Team in charge of:
  • Organizing and running the Openbravo time based quarterly release process
  • Creating all the release deliverables on time with quality
  • Maintain and develop the CI automated test infrastructure used by all the product development organization
  • Maintain and develop other IT systems used developers (Issue Tracker, Code Repository, Livebuilds testing system, Central Repository (module downloads))

Openbravo Services team

Finally, Openbravo offers an implementation framework named "Openbravo Implementation framework", proposed to provide a proven, understandable and scalable guide for Openbravo implementation projects whatever size they are. Every time that a new customer opportunity clearly reach a mature status, an implementation project starts based on the "Services" team work prevously done in regards to opportunity qualification and final proposal.

Openbravo Services team is the team responsible for the configuration/deployment of the Openbravo Commerce solutions on the end-customer site. This team is composed by below listed roles and responsabilities:

• a Project Director in charge of:
  • escalations to the steering comitts, if required
• a Project Manager in charge of:
  • the definition of the initial steps of the projects
  • project process monitoring and team coordination
  • project planning and control
  • project validation and completion
  • change management
  • the identification, monitoring, evaluation and mitigation of risks
  • scope modification management
  • and troubleshooting
• a Technical Lead in charge of:
  • the analisys of all technical requirements
  • the creation of the corresponding Technical Design
  • the development of interfaces, if required
  • the definition and design of unit test and performance test
• Engineers in charge of
  • Technical Design creation in collaboration with the Technical Lead
  • Unit testing and Performance test execution
  • development of interfaces, if required
  • technical training execution
• a Senior Consultant in charge of
  • the analysis of all functional requirementes
  • the creation of the corresponding Functional Specifications
  • the definition of the test plan
  • the definition of all end-user training
• consultants in charge of
  • Functional Specification creation in collaboration with the Senior Consultant
  • the execution of the test plan
  • the execution of all end-user training

Objectives and implementation of the CMS

Openbravo CMS implementation is based on the definition of:

• the objectives to be achieved by each of the activities required to create and distribute the Openbravo cash register solution,
  mainly focusing on the French Fiscal module which is implementing the requirements of the French law for cash registers.
• the indicators to asses if the objectives are being accomplished
• and the actions to prevent or reduce the risks and NCs identified

It is important to remark that each objective and indicator will be monitored and recorded by the person in charge, who will also inform to the persons concerned.

For additional information, review the document Openbravo Compliance Objectives and Indicators v 2.0

Legal and regulatory watch

Same way, the CMS implemented will be updated if the context evolves as the Functional PM Lead, in collaboration with the Openbravo French team located is Lille, are the recipient of the information bulletins of French legislation, such as:

• Le site officiel de l'administration française
• the LNE, Openbravo certification body, through the "lne.news@lne.fr" channel
• Bulletin Officiel des Finances Publiques
• and the direct communication and assistance of M. Clément Henry, LNE Certification Project Manager & Lead Auditor.

Establishment of compliance checks

Openbravo has implemented and will record a set of effective compliance checks for the activities of design & development, installation, configuration, and integration, in order to ensure that the technical requirements of the LNE standard version 1.4 are met and that non-compliance is avoided or detected and corrected.

To get that working Openbravo will provide to:

• the designated "Design & Development" competent persons, with the Design&Development Compliance Checks List Recording Template v 1.0 to review and record the result of these checks by desing & development activities, and for every new release of the French Fiscal module
• and the designated "Services" or "CSU" competent persons, with the Services Compliance Checks List Recording Template v 1.0 to review and record the result of these checks by installing, configuring and integrating activities, and for at least a set of two customer installations in France.

In the event of a non-compliance, it will be required to record the analysis of the cause and the actions taken in order to correct the NC. In such cases, the competent person will have to contact and therefore keep informed, the Functional Team.

Design and development of the collection system

Openbravo design and development process is described in the wiki page Openbravo Design and Development process.

The elements resulting from the design process of the French Fiscal certification is recorded in the below listed documents:

• the Functional Specifications related to compliance with LNE standard v 1.6
• and the associated Test Plans.

The outcome of the development process is:

• a prototype that can be found in Openbravo Live builds, Retail with modules.
• and the recording of the compliance automated test, that can be found running in Openbravo Continuous Integration.

The following elements of the development are defined and recorded in the documents listed below:

• the Agile development method followed.
• the management of the French Source Code
• the fiscal scope of the cash register system, as described in the OB Functional Specification v 6.0
• the management of the nomemclature of the versions as described in the OB Maintenance File v 5.0

Control of subcontractors

Openbravo may subcontract design and development activities on top of Openbravo cash register system feature, but not in the French Fiscal module as this one is being maintained only and exclusively by Openbravo.

Identification and traceability of distribution

Each cash register solution distributed by Openbravo is identified along with the version distributed in the corresponding internal documentation.

Communication with customers

Openbravo will transmit to their Openbravo Web POS (cash register system) users that:

• all documents necessary to the proper operation of the cash register system can be found in the Openbravo French Fiscal wiki page
• Openbravo has already in place a support procedure and will schedule the corresponding trainings
• a description of the way in which tax authorities can acesss the cash's register's data, can be found in the document French Certification User Guide v 2.0
• a Tax Authorities Guide, explaining the way tax authorities can access the cash register's data, and the procedures for checking all data.

Besides the above, Openbravo contracts to end-users will include several clauses to:

• assess that the Openbravo cash register system is complaint with the LNE standards
• provide the certificate approved by the LNE
• assess customer liability commitments vis-à-vis the Finance Law for 2016 (obligation to keep accounts, data conservation, etc...)
• ensure the customer commits to install, configure and use the Openbravo French Fiscal module according to the guidelines and documentation provided by Openbravo.

In any case, Openbravo make sure that all above mentioned documents will be available to internal teams and users, for three years after the final distribution date of the certified cash register system.

Use of the LNE mark - Cash Register System

Hereby, Openbravo undertakes to comply with the conditions for use of the LNE mark, that is:

• not use the certification obtained in a way that could harm the LNE, nor make any declaration or issue any statement over the certification of its products that could be considered as misleading or unauthorised;
• any reference to the certification prior to notification of its issue is prohibited;
• if the certification is withdrawn or its validity expires, reference to this withdrawn or expired certification is prohibited: any means of communication that makes reference to it must cease to be used;
• only make declarations regarding the certification that are consistent with the certificate issued by LNE;
• reproduce the certificates in their entirety, with the annexes, where applicable, if providing them to a third party;
• any reference to the LNE cash register systems certification in advertising, the presentation of any service, as well as commercial documents of any kind that refer to it must feature the following information, as a minimum:
  • the certificate number;
  • the LNE website address.

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Evaluation and improvement of MSC performance

Openbravo assess to:

• monitor the compliance checks defined and recorded for each activity as described in section 5 - Establishment of compliance checks
• handle any identified non-compliance issues through the issues.openbravo.com tool
• monitor the actions implemented to reduce the risk associated with the compliance of the Openbravo cash register system, as described in section 1 - Context
• monitor external services providers, if any

to evaluate and improve the effectiveness of the implemented compliance management system.

Anomaly handling

Openbravo ensures that non-compliance cash register systems will be identified and controlled in order to prevent their distribution and use.
To get that Openbravo will create an entry for each non-compliance issue found in the issues.openbravo.com tool, where it will:

• analyse the non-conformity
  • identify its causes in order to determine whether it is necessary to do anything to eliminate them so that the non-conformity does not occur again
• implement actions that correct the non-conformity

Those non-compliance entries will be assigned to the compliance team by default, for its analysis and management as described above.

Besides the above, Openbravo will:

• evaluate the effectiveness of the actions taken
• update the identified risks in section 1, if necessary
• update the CMS as described in section 5, if necessary

Records management

Openbravo manages all records cited in this standard, as well as all records deemend relevant in the file below.

OB CMS - Records Management v 2.0

Hereby Openbravo commits to ensure the correct storage, protection, duration of conservation and deletion of these records.