0 / 24

Model 13 of 74 · Strategy & Governance

Ethics & Integrity Maturity Assessment

Assess how deeply ethical principles are embedded in organisational culture, decision-making, and governance — from baseline compliance through to principled leadership.

Pillars & areas

Lead

Set the standard

  1. 01Ethical Leadership & Tone from the Top
  2. 02Code of Conduct & Policy

Decide

Apply the principles

  1. 03Ethical Decision-Making
  2. 05Conflicts of Interest

Enforce

Hold to account

  1. 04Reporting & Whistleblowing
  2. 06Accountability & Consequences

Levels

  1. 1Compliance-DrivenRules to avoid penalties
  2. 2Values-LedLeaders model integrity
  3. 3PrincipledEthics defines the org

01 Ethical Leadership & Tone from the Top

How visibly and consistently leaders demonstrate ethical behaviour and set expectations for the organisation.

0/4 answered

EL-1How do senior leaders communicate the importance of ethical behaviour to the organisation?

Think about whether ethics is mentioned only in onboarding or policy documents, or whether leaders actively reference it in everyday communications and decisions.

EL-2How do leaders respond when they become aware of ethical failures within the organisation?

Consider whether leadership treats ethical failures as PR problems to contain, or as systemic issues to understand and address.

EL-3How consistently do leaders apply ethical standards to themselves as they do to others?

Think about whether leaders hold themselves to the same rules — expenses, conflicts, use of resources — or whether seniority comes with unspoken exemptions.

EL-4How do leaders handle pressure to compromise ethical standards for commercial or operational gain?

Consider situations where hitting a target, closing a deal, or meeting a deadline conflicted with doing the right thing.

02 Code of Conduct & Policy

The clarity, accessibility, and practical relevance of ethical policies and codes of conduct.

0/4 answered

CC-1How well does the code of conduct translate ethical principles into practical, everyday guidance?

Think about whether the code reads like a legal document full of prohibitions, or whether it gives people genuine help in navigating real ethical dilemmas.

CC-2How effectively are ethics policies communicated and reinforced beyond initial onboarding?

Consider whether people remember what they signed during onboarding, or whether ethical expectations are reinforced through ongoing engagement.

CC-3How well do ethics policies cover emerging and non-obvious risks such as data use, AI, supplier conduct, and environmental impact?

Think about whether policies only address traditional risks like fraud and bribery, or whether they extend to newer ethical challenges.

CC-4How accessible and understandable are ethics policies for people at all levels of the organisation?

Consider whether a warehouse operator, a software developer, and a finance director would all find the policies relevant and written in language they can understand.

03 Ethical Decision-Making

How well the organisation equips people to recognise, reason through, and resolve ethical dilemmas in their daily work.

0/4 answered

ED-1How confident are staff in identifying when a situation involves an ethical dimension?

Think about whether people recognise ethical issues only when they are obvious — like bribery — or whether they can spot subtler issues like favouritism, data misuse, or conflicts of interest.

ED-2Does the organisation provide a structured approach for working through ethical dilemmas?

Consider whether people have a method to follow when they face a difficult ethical choice, or whether they just rely on gut feeling.

ED-3How well does the organisation support people who face ethical pressure from clients, partners, or internal stakeholders?

Think about a situation where a client asks for something questionable, or an internal stakeholder pushes someone to bend a rule — what support is available?

ED-4How does the organisation learn from past ethical dilemmas to improve future decision-making?

Consider whether resolved ethical issues are filed away, or whether they are turned into case studies, training materials, or policy improvements.

04 Reporting & Whistleblowing

The safety, accessibility, and effectiveness of mechanisms for raising ethical concerns.

0/4 answered

RW-1How safe do people feel raising ethical concerns or reporting misconduct?

Think about whether people genuinely believe they can report an issue without facing retaliation, social exclusion, or career consequences.

RW-2How many independent channels are available for reporting ethical concerns?

Consider whether the only option is telling your line manager, or whether there are genuinely independent alternatives.

RW-3How effectively does the organisation investigate and close reported ethical concerns?

Think about whether reports disappear into a black hole, or whether reporters receive updates and can see that action was taken.

RW-4How does the organisation track and analyse reporting trends to identify systemic ethical risks?

Consider whether individual reports are treated as isolated incidents, or whether patterns across reports are analysed to surface underlying issues.

05 Conflicts of Interest

How the organisation identifies, discloses, and manages situations where personal interests may compromise professional judgement.

0/4 answered

COI-1How clearly does the organisation define what constitutes a conflict of interest?

Think about whether the definition covers only financial interests, or extends to personal relationships, secondary employment, board memberships, and less obvious situations.

COI-2How consistently do people disclose potential conflicts of interest?

Consider whether disclosure happens only when required by a form, or whether people proactively flag potential conflicts as a matter of habit.

COI-3How does the organisation manage disclosed conflicts to prevent them from affecting decisions?

Think about whether a disclosed conflict simply sits in a register, or whether practical steps are taken to remove the conflicted person from the relevant decision.

COI-4How does the organisation handle situations where an undisclosed conflict of interest is discovered?

Consider whether the response focuses on punishing the individual, or on understanding why the conflict went undisclosed and fixing the system gap.

06 Accountability & Consequences

How the organisation ensures ethical expectations are enforced fairly and consistently, with real consequences for breaches.

0/4 answered

AC-1How consistently are ethical breaches met with proportionate consequences, regardless of the individual's seniority or value to the organisation?

Think about whether a high-performing executive and a junior employee would face the same process and range of outcomes for the same breach.

AC-2How well does the organisation recognise and reward ethical behaviour, not just penalise breaches?

Consider whether ethics only comes up when something goes wrong, or whether doing the right thing is actively celebrated.

AC-3How transparent is the organisation about the outcomes of ethical investigations?

Think about whether people know what happened after a reported issue was investigated, or whether outcomes disappear behind confidentiality.

AC-4How does the organisation ensure that ethical accountability extends to third parties such as suppliers, partners, and contractors?

Consider whether ethical standards apply only to employees, or whether the organisation holds its ecosystem to the same expectations.

Self-assessment report

Ethics & Integrity

Answer the questions above and your report builds here: an overall score, a score and target for each area, and the three changes that matter most.

About this model

About the Ethics & Integrity maturity model

Ethics and integrity are not compliance checkboxes — they are the foundation of organisational trust. An organisation that treats ethics as a legal obligation will do the minimum required and hope it is enough. An organisation that treats ethics as a strategic asset will build a culture where people do the right thing because they understand why it matters, not because they fear the consequences of getting caught.

The journey from compliance-driven ethics to principled integrity mirrors organisational maturity itself. Early-stage organisations focus on rules and penalties. Maturing organisations invest in values, training, and support systems. The most advanced organisations make ethical reasoning a reflex — embedded in how they hire, how they make decisions, how they treat stakeholders, and how they respond when things go wrong.

This model assesses the depth to which ethical principles are woven into the fabric of an organisation. It examines not just whether policies exist, but whether they are lived. Not just whether people can report concerns, but whether they feel safe doing so. Not just whether leaders talk about integrity, but whether they demonstrate it when it costs them something.

24 questions across 6 key areas, assessing how deeply ethical principles are embedded in organisational culture, governance, and decision-making. Takes approximately 10-15 minutes to complete.

Designed to be used by governance teams, ethics officers, board members, and senior leaders seeking an honest picture of their organisation's ethical maturity — beyond what audits and compliance reports reveal.

Who this assessment is for

  • Board members and non-executive directors assessing governance strength
  • Chief Ethics Officers and compliance leaders benchmarking programme effectiveness
  • Senior leadership teams evaluating organisational culture and tone from the top
  • Risk and audit committees seeking a qualitative view of ethical health
  • HR and people leaders assessing whether values are lived, not just posted on walls
  • Organisations preparing for regulatory scrutiny, IPO, or public accountability

The three maturity levels

  • Level 1 — Compliance-Driven: Ethics exists primarily as a legal and regulatory obligation. The organisation has policies and a code of conduct, but they function as risk mitigation instruments rather than cultural guides. Ethical behaviour is driven by fear of penalties rather than genuine commitment. Leaders may speak about values in formal settings but do not consistently model them. Reporting mechanisms exist but are underused because people do not fully trust them. Conflicts of interest are managed reactively, and consequences for ethical breaches vary depending on who is involved.
  • Level 2 — Values-Led: The organisation has moved beyond minimum compliance to actively promote and embed ethical values. Leaders visibly model integrity and reference ethical principles in decision-making. The code of conduct is a practical tool, not just a legal document. Staff are trained to recognise and reason through ethical dilemmas, and multiple reporting channels are available and reasonably trusted. Conflicts of interest are systematically managed, and consequences for breaches are applied consistently. Ethics is part of how the organisation talks about itself — and increasingly, how it actually operates.
  • Level 3 — Principled: Ethics is a defining characteristic of the organisation — a source of competitive advantage and stakeholder trust. Ethical reasoning is embedded in strategy, product design, procurement, and partnerships. Leaders hold themselves to a higher standard than they expect of others, and the organisation has a visible track record of choosing integrity over expediency. Reporting is normalised, investigations are rigorous and transparent, and ethical behaviour is recognised and rewarded. The organisation extends its ethical standards across its entire ecosystem, including suppliers and partners, and proactively addresses emerging ethical frontiers before they become crises.

The 6 areas assessed

  1. Ethical Leadership & Tone from the Top — How visibly and consistently leaders demonstrate ethical behaviour and set expectations for the organisation.
  2. Code of Conduct & Policy — The clarity, accessibility, and practical relevance of ethical policies and codes of conduct.
  3. Ethical Decision-Making — How well the organisation equips people to recognise, reason through, and resolve ethical dilemmas in their daily work.
  4. Reporting & Whistleblowing — The safety, accessibility, and effectiveness of mechanisms for raising ethical concerns.
  5. Conflicts of Interest — How the organisation identifies, discloses, and manages situations where personal interests may compromise professional judgement.
  6. Accountability & Consequences — How the organisation ensures ethical expectations are enforced fairly and consistently, with real consequences for breaches.

How this model relates to other frameworks

  • UK Corporate Governance Code (Financial Reporting Council) — board leadership and company purpose
  • US Federal Sentencing Guidelines — effective compliance and ethics programmes
  • ISO 37001 Anti-Bribery Management Systems
  • ISO 37301 Compliance Management Systems
  • OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
  • Transparency International Business Integrity Toolkit
  • Institute of Business Ethics (IBE) — ethics programme benchmarking
  • Ethics & Compliance Initiative (ECI) — Global Business Ethics Survey research
  • Sarbanes-Oxley Act Section 301 — whistleblower protections and audit committee responsibilities

Frequently asked questions

What is the Ethics & Integrity maturity model?

Assess how deeply ethical principles are embedded in organisational culture, decision-making, and governance — from baseline compliance through to principled leadership. It is an original, simplified model with three maturity levels (Compliance-Driven, Values-Led and Principled), assessed through 24 questions across 6 areas: Ethical Leadership & Tone from the Top, Code of Conduct & Policy, Ethical Decision-Making, Reporting & Whistleblowing, Conflicts of Interest and Accountability & Consequences.

How long does the Ethics & Integrity assessment take?

Most people finish in 10–14 minutes. Each of the 24 questions has three concrete answer options. Your progress is saved in the page URL, so you can bookmark it and come back later.

How is the score calculated?

Each answer scores 1 (Compliance-Driven), 2 (Values-Led) or 3 (Principled). An area's score is the average of its answered questions, and the overall score is the average of the area scores, so every area counts equally. Scores run from 1.0 to 3.0.

Is my data stored or shared?

No. Your answers are never sent to a server. They are stored only in the page URL, which you control. Copy the link to share results with colleagues, or export a PDF or CSV report.

How should I use the results?

Start with "Where to focus" in your report. It lists the questions with the biggest gap to the target you set for each area, and shows what the next level looks like in practice. For a fuller picture, ask several people from different teams to complete the assessment and compare their links. Differences in perception are often as revealing as the scores themselves.