How do you evidence it?
Good intentions are no longer sufficient. The 2024 FRC Code has shifted the standard from process to outcomes.
Boards are now required to demonstrate that governance decisions actually influenced strategy, risk management, and culture — not merely that the right processes existed. This stage gives you the tools to build the evidence trail that demonstrates accountability has been discharged. Three routes are available. All reach the same place.
Submit your Stage 1 and Stage 2 outputs alongside your completed Stage 3 worksheets. AI reads everything together, identifies where the evidence trail is strong and where it has gaps, and returns a structured evidence framework — what exists, what is missing, and what needs to be built.
Here is the prompt sequence, in full:
AI works with what it is given. It will assess the evidence that has been submitted — it cannot identify what is missing from the submission itself. For full details of how AI is used in this platform, see our AI & data policy.
Download AI submission template (Word)Submit your work for AI analysis →
A One Degree consultant reviews your board's governance record — minutes, decision logs, governance statements, delegation framework — and tells you honestly what the evidence trail demonstrates to an external reviewer, and what it does not. As ARGA's powers expand, the standard will only rise.
- Board minutes reviewed for quality, reasoning, and completeness
- Governance statement drafted or reviewed against the 2024 FRC Code standard
- D&O insurance cover reviewed against actual accountability carried
- Outcome-based reporting framework built for annual governance reporting
- Structured output: evidence framework, gaps identified, actions required
Work through the tools below. The statutory tools address the legal evidence requirements — minutes, governance statements, D&O cover. The conduct tools address the emerging standard: outcome-based evidence and public commitment to the IoD Code.
Apply a simple test to each piece of evidence: would it satisfy an external reviewer that accountability has been actively and specifically discharged? If the honest answer is no, it needs to be strengthened.
Board minutes are the primary legal record of how the board has discharged its statutory duties. Minutes that record only attendance and outcomes — without the reasoning, challenge, and discussion that led to decisions — are a governance liability. In a regulatory investigation or legal challenge, poor minutes do not protect directors. They raise questions.
- Do the minutes record the reasoning behind significant decisions — not just the outcome?
- Is challenge and dissent recorded where it occurred?
- Are conflicts of interest and their management noted in relevant minutes?
- Are the minutes approved promptly and signed? Are they stored securely and accessibly?
- Would an external reviewer reading the last twelve months of minutes conclude that the board was actively and thoughtfully discharging its duties?
An annual governance statement sets out, in plain language, how the board has discharged its accountability over the year — strategic decisions made, oversight exercised, risks managed, culture maintained. The 2024 FRC Code requires evidence of outcomes, not just a description of processes. A governance statement that describes what committees exist and how often they met is not meeting the standard.
- The significant decisions the board made — and the outcomes they produced
- How the board provided challenge and oversight — with specific examples
- How the board engaged with stakeholders — and what it did as a result
- How risks were identified, assessed, and managed — at board level
- Where the board fell short of its own standards — and what it has done about it
Directors and Officers insurance provides cover for legal costs and claims arising from alleged wrongful acts in a director's capacity. As accountability requirements tighten — and as ARGA's investigatory powers expand — adequate D&O cover is an increasingly important protection for individual directors. Cover gaps are more common than most boards realise, particularly where the organisation has grown or its activities have changed.
- Does current D&O cover reflect the organisation's current size, activities, and risk profile?
- Does it cover all directors — including NEDs and any shadow directors?
- Does it cover regulatory investigations — not just civil claims?
- When was the cover last reviewed? Has anything changed that would affect adequacy?
The 2024 FRC Code's new Principle C requires governance reporting to focus on board decisions and their outcomes — not on a description of structures and processes. An outcome-based reporting framework structures the board's accountability record around what it decided and what happened as a result, rather than what committees it has and how often they met.
- For each significant board decision in the year: what was decided, what information informed it, what happened as a result?
- For each major risk: how did the board identify it, what oversight did it apply, what changed as a result of board-level attention?
- For each stakeholder group: what engagement took place, what did the board hear, what did it do differently as a result?
- For culture and ethics: what evidence does the board have that the culture it expects is the culture that exists?
The IoD Code of Conduct encourages boards to publicly commit to its six principles — in annual reports and on company websites. This is a voluntary act, but it carries real weight: it signals to investors, regulators, and stakeholders that the board holds itself to a standard beyond the legal minimum, and it creates a public accountability that the board must then be prepared to evidence.
- A board resolution to commit to the IoD Code — recorded in the minutes
- A brief statement in the annual report or on the company website confirming the commitment
- An annual review of how the board has discharged each of the six principles — with honest assessment of where it fell short
- The commitment should be made only when the board is confident it can evidence compliance — a public commitment that cannot be substantiated is worse than no commitment at all
The board builds its evidence trail from its own decisions, deliberations, and oversight — not from management reports. Management reports are evidence of what the Exec has done. They are not evidence of what the board has done with that information.
- Board minutes — decisions and the reasoning behind them
- Governance statements — outcomes produced by board decisions
- Challenge and dissent recorded in the minutes
- The board's own self-assessment and improvement record
- Management accounts and operational reports
- Risk registers and control frameworks maintained by management
- Performance data reported to the board
- Compliance returns and regulatory filings
The board uses the Exec's evidence to discharge its accountability. But the board's own evidence of how it exercised oversight and judgement on that information is separate — and it is the board's responsibility to maintain it.
The Accountability pillar is done. Return to the dashboard to choose your next focus area — or continue to the Performance pillar.
Back to dashboard → Start Performance →