GOV-04 · Governance and Accountability

Code of conduct and ethics affirmation

Expected conduct is published and affirmed by staff on joining and annually.

3frameworks fully address it
4partially
1leave it out
SOC 2 ISO 27001 NIST CSF PCI DSS HIPAA GDPR EU AI Act NIST AI RMF
1Where each framework asks for it
  • SOC 2FullCC1.1
  • ISO 27001PartialA.6.2 Covered through terms of employment rather than a separate code.
  • NIST CSFPartialGV.RR-04 Addressed through workforce expectations.
  • PCI DSSPartial12.6 Framed as security awareness acknowledgement.
  • HIPAAFull164.308(a)(1)(ii)(C)
  • GDPRAbsent No conduct code obligation; confidentiality of processing staff is required under Art. 28(3)(b) instead.
  • EU AI ActPartialArt. 4 AI literacy duty touches conduct without a code.
  • NIST AI RMFFullGOVERN 3.2

Build the control once against this objective and cite the clause each auditor asks about. A partial mapping says what the framework leaves out; an absence is a finding about the framework, not a gap in your program.

2What usually proves it

Code of conduct, affirmation records, disciplinary process.

?Why it exists

Culture is what people affirm and what leadership enforces.

For a smaller organizationSigned on joining, re-affirmed each year at review time.