The Board and Executive Leadership of the Member Organisation is ultimately responsible for creation of a Counter-Fraud Programme; providing leadership and direction; and projecting a Counter-Fraud culture inside and outside the organisation. The programme should include a Counter-Fraud Strategy to define organisational objectives, a Counter-Fraud Policy outlining responsibilities and mandatory requirements, and a Governance Structure with associated internal and external reporting aligned to the organisation's size and complexity to monitor and oversee fraud risk management.
Figure 4 - Governance Domain