Ethical leadership is regarded as the key to building trust and sustaining organisations. However, monitoring
the effectiveness of organisations in promoting ethical leadership poses a challenge to assurance providers, in
particular internal auditors. Although attempts have been made to provide internal auditors with guidelines on
how to assess the tone-at-the-top, these efforts are still based on the traditional compliance approach that in
the past has fallen short of expectations when applied to questions of ethics. This paper proposes additional
dimensions, to be included in a value-based approach to the assessment of ethical leadership. The foundation
on which these dimensions are assessed is the Integrated Control Framework prepared by The Committee of
Sponsoring Organisations of the Treadway Commission (COSO).