1.09

Control Environment

Principle 1: Demonstrate Commitment to Integrity and Ethical Values

Attribute 1.09: Management uses established standards of conduct as the basis for evaluating adherence to integrity and ethical values across the organization. Management evaluates the adherence to standards of conduct across all levels of the entity. To gain assurance that the entity's standards of conduct are implemented effectively, management evaluates the directives, attitudes, and behaviors of individuals and teams. Evaluations may consist of ongoing monitoring or separate evaluations. Individual personnel can also report issues through reporting lines, such as regular staff meetings, upward feedback processes, a whistleblowing program, or an ethics hotline. The oversight body evaluates management's adherence to the standards of conduct as well as the overall adherence by the entity.

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Jamie's Story

November 2022: Mid-term Election

From Attribute 1.07: Maricopa County management, with Katie Hobbs' oversight, were responsible when numerous election anomalies occurred during the 2020 General Election. Governance issues were identified in this assessment under "Election Anomalies" which used the Arizona Attorney General's Office 2020 General Election Investigation as objective information to identify governance issues. Katie Hobbs was accused of being unethical in her decision to not recuse herself from her Election Oversight responsibilities during the 2022 Mid-term election. Similarly, Maricopa county employees displayed unethical behavior by violating election procedures (See Dropbox Collection - 2020). Like Katie Hobbs, MC election personnel were not violating any laws, they were just violating the Election Procedures Manuals, Interestingly, Katie Hobb's was responsible for those procedurs as the Arizona Secretary of State in 2020.

Relevant to this Attribute, 1.09, there is no eveidence was found to demonstrate Katie Hobbs was evaluating county election management's adherence to the standards of conduct for substandard performance in 2020.

June 8, 2026: Arizona State Ombudsman Replies

Maricopa County's Ombudsman are ethically deficient to Arizona State Ombudsman. Maricopa County has job positions with Ombudsman in the title. However, Maricopa County Ombudsmen 1) are not trained as Ombudsman, 2) are not operating within an internationally recognized process for Ombudsman, and do not have their independence legally established by statute or county ordinance.

Maricopa County's Ombudsman do not receive the same degree of training as the Ombudsman for Arizona Ombudsman Citizens' Aide (AZOCA) agency. AZOCA Ombudsman have been trained in accordance with the standards of the United States Ombudsman Association (USOA). The AZOCA Representative did not believe the Maricopa Ombudsman by USOA or any other internationally recognized Ombudsman organization. Additionally, Maricopa County does not follow the Model Act, which was established by the USOA and endorsed by the Coalition of Federal Ombudsmen (COFO) and other international ombudsman organizations. The standard exists for Ombudsmen programs; however, Maricopa County is not applying the standard. Ironically, deviations from standards in other areas is inhibited by the lack of an effective Ombudsmen program.

Election Anomalies

Maricopa Dropbox Collection (2020)

Governance issues identified from Arizona Attorney General's Office 2020 General Election Investigation of Arizona Senate allegations of Maricopa County Election Department - Drop Box Collections issues. Five procedure violations were identified. However, it is impossible to determine the impact to prevent, detect and subsequently investigation potential fraud from an unknown number of ballots affected by these violations.

• See the heading Deviation: Missing Entries on Election Forms from Maricopa Dropbox Collection (2020) webpage.
• See the heading Deviation: Missing Ballot Counts from Maricopa Dropbox Collection (2020) webpage.
• See the heading Deviation: Used Email instead of EVBTS Forms from Maricopa Dropbox Collection (2020) webpage.
• See the heading Deviation: Unfulfilled Party Representation Requirements for Couriers from Maricopa Dropbox Collection (2020) webpage.
• See the heading Deviation: Fictious Addresses in MC Voter Registration Database from Maricopa Dropbox Collection (2020) webpage.
• See the heading Deviation: Allegations Confirmed from Maricopa Dropbox Collection (2020) webpage.
• See the heading Noteworthy: Consequences Unknown from Maricopa Dropbox Collection (2020) webpage
• See the heading Noteworthy: Transmission of USPS Data to MC and Runbeck from Maricopa Dropbox Collection (2020) webpage