Use cases by role
Compliance: individual evidence, not a circular
Dated, individual acceptances, third-party screening and audit-ready evidence.
A compliance programme is judged on what it can demonstrate, not on what it says it does. And the gap between the two is almost always in the same place: emailing a circular to the whole workforce is an action; holding each person's individual, dated acceptance is evidence.
Acceptances that work as evidence
Code of ethics, anti-bribery policy, gifts policy, systems usage, whistleblowing channel. They all share one requirement: you must be able to demonstrate that a specific person accepted it on a specific date. An individual signature does that; an email read receipt does not.
Third parties: the most neglected point
Liability does not stop at your own front door. The suppliers, distributors and agents you work with are part of the perimeter, and demonstrating that they were screened — and against what criteria — is what gets asked for when something goes wrong.
| What you ask the third party for | What it is for |
|---|---|
| Acceptance of the group code of ethics | Extends the standard beyond your own workforce |
| Beneficial ownership declaration | It is what gets reviewed when a conflict surfaces |
| Conflict of interest declaration | Renewed annually, not just at onboarding |
| Their own certifications and policies | Supports the ESG criterion with documents, not assertions |
Watch out
Declarations do not last forever. A conflict of interest declaration signed four years ago says nothing about the current situation, and that date is exactly what an investigator looks at.
Training: record that it happened, not that it was offered
Same as with policies. The useful evidence is not the training material or the invitation: it is the list of who completed it, with dates, signed by each of them.
Frequently asked questions
›How do I prove someone accepted a specific policy?
With their individual signature on that document, carrying its date and the record of how it was signed. That is what you produce if it is ever disputed.
›Can I re-issue declarations automatically each year?
Yes, by scheduling the send. It goes only to whoever is due, without rebuilding the circuit.
›What if an employee refuses to sign?
The refusal is recorded with their reason, which for programme purposes is also evidence: it is on record that they were asked and what they answered.
›Does it help evidence the whistleblowing channel?
For the documentary side yes: communication of the channel, acceptance of the policy and traceability of actions. The channel itself is a separate thing.
A real case
The situation
A compliance audit asks for proof that all 140 employees accepted the updated code of ethics.
What you do
- Filters the signatures on that document
- Exports the list with each acceptance's name and date
- Flags the four outstanding and who has been reminded
What you get
Individual, dated evidence for 136 people, instead of an email sent to a distribution list.
The situation
A circular is sent and everyone is considered trained.
What you do
- Asks for individual signature and tracks status
What you get
The evidence is per person.
The situation
An auditor asks for evidence and is shown the sent email.
What you do
- Shows who signed and when
What you get
The control moves from assertion to evidence.
The situation
Training repeats yearly and the send is rebuilt.
What you do
- Reuses the previous year's process
What you get
The campaign is prepared in an afternoon.
The situation
Somebody joins mid-year and receives nothing.
What you do
- Launches the process at onboarding
What you get
Nobody is left out.
The situation
Nobody knows who is still to sign.
What you do
- Checks the status per person
What you get
Only those outstanding are chased.
This article answers
- prove an employee accepted the code of ethics
- third-party compliance and ESG screening
- evidence for a compliance audit
- compliance training records
- conflict of interest declarations