CC1.1 Commitment to integrity and ethical values (COSO principle 1)
The organisation shows through direction, decisions and behaviour that integrity and ethics matter to how it runs its controls. Points of focus: leadership sets the tone at the top; expected conduct is written into a code that staff, outsourced providers and partners understand; performance of individuals and teams is judged against that code; departures from it are found and corrected promptly and consistently; and contractors and vendor staff are brought within the same conduct expectations, adherence checks and corrective action.
Source: SOC 2 (2017 Trust Services Criteria), CC1.1. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open SOC 2 (2017 Trust Services Criteria) in the compliance library.
These are criteria, not controls: you design controls that meet them, and which criteria are in scope follows the categories your report covers (Security always; Availability, Confidentiality, Processing Integrity and Privacy only if chosen). A Type 2 report tests that the controls operated across the period, so the evidence asked for is samples across that period, not one copy.
These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Signed acknowledgements of the code at hire and annually, including for contractors · HR system / LMS
- Records of conduct breaches investigated and the disciplinary or corrective outcome · HR system / LMS
governing documentDocuments that govern the control
- Board-approved code of conduct with version history and scope covering contractors and vendor staff · Policy repository / GRC workspace
- Leadership communications or town-hall material setting expectations on integrity · Policy repository / GRC workspace
First move
Common gaps auditors find
- Code of conduct never acknowledged by contractors or vendor personnel
- No evidence that reported violations were investigated or closed
- Acknowledgements collected at hire only, never refreshed
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 Disposing of confidential information · CC1.2 Board independence and oversight of internal control (COSO principle 2)