Baltrenas

BACKGROUND

Kaiser hired Baltrenas in 1985 as an analyst in its Information Services Department. Baltrenas primarily worked in the Core Finance Systems group (CFS), which maintains and operates financial software applications used by the business arms of Kaiser. Each business arm using one of CFS’s financial applications “owns” the application’s software and is called a “Business Application Owner” (BAO).1 Only the BAO may approve changes to or tests on its software’s coding. In addition, any changes to or tests on that software must also comply with Kaiser’s internal policies, including its “Sarbanes-Oxley controls” (SOX controls).2 The SOX controls require personnel to acquire and document specific types of authorization for testing, coding, or data manipulation. “The primary goal” of these controls “is to manage the initiation, review, testing, approval, and implementation and documentation of all proposed changes,” in part, to “[e]nsure changes do not adversely impact key financial data and controls.” Two SOX controls are at issue here, controls 12.14.03 and 12.15.01. SOX control 12.14.03 requires that “[b]usiness, technical and security change requests are required to

1 The…