CC1.1 COSO principle 1: Demonstrates commitment to integrity and ethical values
Demonstrates a commitment to integrity and ethical values.
5
artefacts
1
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Acknowledgement records from personnel, contractors and, where relevant, vendors, covering the full population in the period · HR system / LMS
periodic reviewEvidence produced at each review
- Records of the whistleblower or ethics reporting channel, including its independence and evidence of use · Policy repository / GRC workspace
- Evidence of evaluation of adherence and of deviations addressed in a timely manner, including the outcome of investigated matters · Cloud console / configuration management
governing documentDocuments that govern the control
- The code of conduct or ethics policy, with evidence of board or senior management approval · Policy repository / GRC workspace
- Evidence standards of conduct are communicated on an ongoing basis, not only at hire · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your HR system / LMS on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Code of conduct exists with acknowledgement captured for employees only, leaving contractors with system access uncovered
- No evidence any deviation was ever identified, which auditors read as absence of monitoring rather than absence of issues
- Ethics hotline available but no record of how reports are triaged, by whom, or whether anonymity is preserved
- Consequences for deviation described in policy with no example of them being applied
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetC1.2 Confidential information is disposed of securely · CC1.2 COSO principle 2: Board exercises oversight responsibility