12.01

Control Activities

Principle 12 - Implement Control Activities

Attribute 12.01 - Management should implement control activities through policies and procedures.

Attributes

The following attributes contribute to the design, implementation, and operating effectiveness of this principle:

• Documentation of Control Activities Through Policies and Procedures
• Periodic Review of Control Activities

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Jamie's Story

November 20, 2025: Debbie Lesko Presentation

Debbie Lesko provides an oversight role as a member of the Maricopa County Board of Supervisors (MCBOS). Her presentation of why two boxes of ballots could not be located for three days following a November 2025 election parroted the Election's Department statementfrom November 7, 2025. She seemed to be accepting of people not following procedures to place the boxes of ballots in an unauthorized location for transport and how fortuitous it was that they had coincidently been stored in an area with 24-hour surveillance. Hence, a person in an oversight role did not communicate that management would be held accountable to address this ongoing issue with election processes.

Election Anomalies

Arizona Senate Allegations

Arizona Senate allegations arose from MC's failure to recognize the Arizona Senates Oversight Role. These allegations were investigated and reported on by the Arizona Attorney General's Office 2020 General Election Investigation. The AZ AG's inspector relied on interviews to determine Information Technology (IT) practices. Evidently, no procedures were available for the inspector's review. Documented procedures ensure consistency in operations. This governance gap is most relevant to the indeterminate findings of the investigation, which are as follows:

• Maricopa Election Management Server (2020)
  • MC EMS 2020 - Election Management System Database Purged
  • MC EMS 2020 - Election Files Deleted
  • MC EMS 2020 - Corrupt Ballot Images
  • MC EMS 2020 - Missing Ballot Images
  • MC EMS 2020 - Anonymous Logins
  • MC EMS 2020 - Dual Boot System Discovered
  • MC EMS 2020 - Operating System Logs Not Preserved

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. Section 2 of the AZ AG's inspector's report identified five procedure violations. See the heading Deviation: Allegations Confirmed from Maricopa Dropbox Collection (2020) webpage for additional details. This finding was based on the following:

• 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.

Maricopa County Signature Verification (2020)

Governance issues identified from Arizona Attorney General's Office 2020 General Election Investigation of Arizona Senate allegations of Maricopa County - Signature Verification Process issues. In Section 2 of the AZ AG's inspector's report, it is noted that 33 MC employees received signature verification training, which mirrored the Arizona Secretary of State's recommendation from the Election Procedure Manual (EPM). However, it is later noted that 40 temporary workers performed Level 1 Signature Verifications, but were hired after training was implemented. Apparently, these 40 temporary workers performed signature verifications without the training as recommended in the EPM.

2020 Maricopa County Directs Use of Sharpie Pens

The Maricopa County Assistant Director of Recruitment and Training directed unethical activities, defeating an internal control. The leader informally instructed personnel using email to use Sharpie Markers on Election Day, despite known issues and concerns with the Sharpie Markers. This senior management person was interfering with internal controls.