The correct answer is B because the first step is to define expected ethical behavior. A policy establishes the standard, responsibilities, required conduct, and prohibited conduct. After the policy exists, the organization can train employees, communicate sanctions, and establish reporting or incentive mechanisms. ISACA describes policies as documents that formally communicate required and prohibited activities and behaviors to guide enterprise operations and compliance requirements.

This is also consistent with ISACA’s Code of Professional Ethics, which guides professional and personal conduct, requires high standards of conduct and character, and states that failure to comply can lead to investigation and disciplinary measures. The uploaded CRISC notes further support that developing and practicing ethical behavior contributes most to building risk culture and that ethics awareness training supports professional ethics after expectations are established.

A, C, and D are useful supporting activities, but they should follow the policy. Training cannot be effective until the expected ethical behavior is defined, and sanctions or incentives should be based on the established ethics policy.