Publication - Advice and guidance
Counter Fraud Maturity Model
The Counter Fraud Maturity Model provides guidance on how mature your counter fraud controls are.
Counter Fraud Maturity Model
| Counter Fraud Controls | Initial | Developing | Established | Progressive | Leading |
|---|---|---|---|---|---|
| Ethics | Ethical standards are in place and communicated but are not comprehensive. | Clear ethical standards are in place including a formal counter fraud policy. | Clear ethical standards are in place through a formal counter fraud policy, and codes of conduct. | Clear ethical standards are promoted through a formal counter fraud policy, and codes of conduct including the prevention of bribery and corruption. | Counter fraud policy is embedded within the overall organisational strategy and business planning. |
| Policies | A fraud response plan is in place. | A fraud response plan is in place alongside other policies such as register of interests. | A fraud action plan is in place alongside other policies such as register of interests. | Fraud is dealt with effectively through implementation of a comprehensive fraud action plan, and other policies such as register of interests. | Focus is on continual improvement in updating policies regularly to respond to, and communicate, any changes to governance standards. |
| Training & Development | Guidance in preventing fraud, bribery and corruption is available to staff. | Guidance in preventing fraud, bribery and corruption is available to staff. Training is promoted but not supported corporately. | Guidance and training in preventing fraud, bribery and corruption is available to staff. | All staff and stakeholders are supported in their responsibilities in preventing fraud, bribery and corruption through guidance and training. | Knowledge and skills are updated regularly keeping up to date with any changes to professional standards. |
| Risk Assessment | Fraud risk assessments are ad hoc. | Fraud risk assessments are undertaken in key areas of the organisation. | Fraud risk assessments are undertaken across the organisation. | Fraud risk assessments are comprehensive and undertaken across the organisation. | Fraud risk assessments are embedded within the overall organisational risk assessment processes. |
| Monitoring Controls | Designing, operating and reviewing internal controls are not integrated. | Managers are encouraged to counter fraud designing, operating and reviewing internal controls. | Support is available for designing, operating and reviewing internal controls. | Managers are provided with specialist support in designing, operating and reviewing internal controls. | Using data, and technology, efficiently in current and future systems, to combat fraud and error. |
| Reporting Arrangements | Processes for reporting suspicions of fraud are not clear. | A process is in place for reporting suspicions of fraud. | Protecting members of staff through a robust process for reporting suspicions of fraud. | Members of staff are protected through a robust process for reporting suspicions of fraud, bribery and corruption. | Quantitative and qualitative reporting of fraud metrics is in place for the organisation. |
| Investigation & Response | Allegations of fraud are investigated as a priority as resources allow. | All allegations of fraud are investigated. | All allegations of fraud are investigated by skilled staff. | A comprehensive and coordinated approach is applied to all allegations of fraud including professional investigation by skilled staff. | High-risk areas are proactively assessed and analysed for potential fraud by professionally trained staff. |
| Communication | Communications to deter fraud are issued occasionally to staff. | The commitment to deter fraud is communicated by raising awareness of policies to staff. | The commitment to deter fraud is communicated by raising awareness of policies to all staff on a regular basis. | The commitment to deter fraud, bribery and corruption is communicated by raising awareness of policies to all staff on a regular basis. | Comprehensive communication lines in place to deter fraud, bribery and corruption by raising awareness of policies to all staff and stakeholders. |
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