1.04

Control Environment

Principle 1: Demonstrate Commitment to Integrity and Ethical Values

Tone at the Top

Attribute 1.04: The oversight body's and management's directives, attitudes, and behaviors reflect the integrity and ethical values expected throughout the entity. The oversight body and management reinforce the commitment to doing what is right, not just maintaining a minimum level of performance necessary to comply with applicable laws and regulations, so that these priorities are understood by all stakeholders, such as regulators, service organizations, employees, and the public.

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Jamie's Story

No examples available to illustrate governance gaps for this attribute.

Election Anomalies

Arizona Senate Allegations

As already noted in Green Book Attribute 1.01, 1.02, and 1.03 Arizona Senate allegations arose from a 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 elected officials were considered as a possible oversight entity for MC operations.

This Green Book attribute emphasizes the need to "commitment to doing what is right, not just maintaining a minimum level of performance necessary to comply with applicable laws and regulations, so that these priorities are understood by all stakeholders, such as regulators, service organizations, employees, and the public," MC Elected Officials and MC leadership were apparently doing less than the minimum given their position that the Arizona Senate was not entitled to perform oversight. Hence, the oversight and management were both demonstrating a lack of integrity and unethical behavior in the eyes of the public because of their lack of transparency. This potential deviation from the Green Book standard applies to the following Arizona Senate Allegations:

• Maricopa Dropbox Collection (2020)
• 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 - Failure to Follow Basic Cyber Security Practices
  • MC EMS 2020 - Subpoenaed Equipment Not Yet Provided
  • MC EMS 2020 - Anonymous Logins
  • MC EMS 2020 - Dual Boot System Discovered
  • MC EMS 2020 - Operating System Logs Not Preserved
  • MC EMS 2020 - Internet Connections to the EMS

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.

The allegation was raised by the Arizona Senate in 2021, which indicate MC was not adequately responding to regulators in their oversight role.

The Arizona Senate was alerted to documentation discrepancies by Verity the Vote, which was lead by two citizens. Maricopa was unable to resolve issues raised by members of the public, which is why they took their concerns to the Arizona Senate for follow up.

MC violated the Arizona Secretary of State's Election Procedure Manual and their own Maricopa County Election Procedures, which were written to ensure compliance with Title 16 - Elections and Electors.

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. Some observations related to management's directives, attitudes, and behaviors reflect the integrity and ethical values expected throughout the entity. Management appeared to be directing a minimum level of performance, rather than direct behaviors that instilled public confidence in the County's activities. Maricopa County trained 29 and 4 part-time MC employees in June 2020 to fulfill the role of Level 1 Signature Verifier. Four months later, 40 temporary employees were hired and performed Level 1 Signature Verifier duties without any training. Therefore, 55% of the Level 1 signature verifiers were untrained.