Column 1 COSO Component Control Environment Column 2 COSO Principle 1. The organization demonstrates a commitment to integrity and ethical values. Column 3 Points of Focus The board of directors and senior management set the proper tone at the top Establishes standards of conduct Evaluates adherence to standards of conduct Addresses deviations in a timely manner Column 4 Controls Present 15 Column 5 Missing or inadequate internal controls (i.e., gaps) There should be evidence that the board of directors is involved in, or reviews the results of, the annual Code of Conduct update. Management or internal audit should test to ensure that all employees complete the annual re-assessment. There should be a timeframe specified for addressing deviations from the standards of conduct. 2. The board of directors demonstrates independence from management and exercises oversight of the Establishes oversight responsibilities 1, 3, 17, 27, Applies relevant expertise development and performance Operates independently of internal control. Provides oversight for the system of internal control