Defence file — board pack (DRAFT)
Northwind Group plc — ECCTA failure-to-prevent-fraud
- Prepared for:
- Audit & Risk Committee, 2026-07-02
- Owner:
- Head of Compliance (S. Patel)
- Generated:
- 2026-06-13
- Export version:
- 1
Decision requested
Approve the revised remediation dates for the two open principle gaps (Due diligence 2026-06-20; Monitoring & review 2026-06-27), or escalate the slippage to the next cycle. No assurance on legal adequacy is requested or implied — that remains with counsel and advisers.
For information
Five of the six principles are mapped and reviewed (evidence coverage 90/100, up from 74 (illustrative) at the 2026-06-06 review and 61 at the 2026-05-09 review) and two items remain in the named review queue. Coverage measures how complete the file is, not defence strength. The export below is a point-in-time snapshot, sealed by the hash in the integrity footer.
Evidence coverage
90/100
Weighted share of the six Home Office principles with mapped, reviewed evidence. A coverage measure of how complete the file is — not a judgement on whether procedures are reasonable, and not a measure of defence strength.
| Principle | Status | Mapped evidence |
|---|---|---|
| Top-level commitment(weight 20) | Mapped | Board minutes 2026-Q1, anti-fraud policy v4 |
| Risk assessment(weight 20) | Mapped | Group fraud risk assessment 2026-03 |
| Proportionate procedures(weight 20) | Mapped | Control matrix, procurement procedure |
| Due diligence(weight 15) | Gap | Supplier refresh evidence outstanding |
| Communication & training(weight 15) | Mapped | All-staff ECCTA briefing 2026-06, training export 92% complete |
| Monitoring & review(weight 10) | Mapped | Quarterly ECCTA readiness board review 2026-Q2 |
Evidence by principle
Per-principle breakdown of mapped evidence with source dates and named reviewer attribution. Items without a reviewer are still in draft; the gap entry shows what is still outstanding.
Top Level Commitment
- Board minutes — fraud agenda item (2026-Q1) (board_minutes, 2026-05-12) — Approved by J. Marsh
- Anti-fraud policy v4 (policy, 2026-05-14) — Approved by J. Marsh
Risk Assessment
- Group fraud risk assessment (2026-03) (risk_register, 2026-05-14) — Approved by J. Marsh
Proportionate Procedures
- Control matrix v2 (policy, 2026-05-20) — Approved by J. Marsh
- Procurement procedure (contract, 2026-05-20) — awaiting review
Due Diligence
Gap: Supplier due-diligence refresh evidence not yet uploadedRecommended: Updated third-party attestation from each active supplier
- Supplier due-diligence attestation (pending refresh) (third_party_attestation, 2026-05-18) — awaiting review
Communication
- All-staff ECCTA anti-fraud briefing — June 2026 (policy, 2026-06-10) — Approved by J. Marsh
- 2026 staff training export (92% complete) (training_record, 2026-05-28) — Approved by J. Marsh
Monitoring And Review
- Quarterly ECCTA readiness board review — Q2 2026 (board_minutes, 2026-06-10) — Approved by J. Marsh
Open blockers
The pack is gated until these are cleared. A forced export still carries every blocker reason into the manifest — the board sees the state of work, not a polished summary.
- Due diligence — supplier refresh evidence missingOwner: Procurement lead (A. Okafor) · Due 2026-06-20
- 2 evidence items still awaiting named review sign-offOwner: Compliance reviewer (J. Marsh) · Due 2026-06-18
Named review sign-off
Each evidence item stays draft until a named reviewer records a decision. Every decision keeps reviewer, timestamp, the automated draft suggestion, and the human note in the audit trail.
Approved
J. Marsh — Compliance reviewer
Approved 7 of 9 items · 2026-06-13
Pending
2 items awaiting sign-off
Pack not yet eligible for a “ready” status.
Owner attestation
“I confirm this pack reflects the evidence state recorded in the workspace as at 2026-06-13, with the one open gap (due diligence supplier refresh) and two pending review items shown above.”
S. Patel — Head of Compliance (first-line owner). Internal Audit (R. Singh, third line) provides independent assurance over the process and does not co-sign the owner attestation.
Reporting line: first-line owner (Compliance) → Audit & Risk Committee, with Internal Audit (third line) as independent assurance reviewer. Unresolved blockers escalate to the committee with their owner and date attached.
Source register (9 items)
Every source is SHA-256 hashed at upload, over the original uploaded bytes. The hash travels into the register and is sealed by the export hash below — so an adviser can confirm a source is unchanged since upload (which file was relied on), not that the uploaded file is itself authentic.
| Source | Uploaded | Status | SHA-256 |
|---|---|---|---|
| Board minutes — fraud agenda item (2026-Q1)board_minutes | 2026-05-12 | approved | 9f2c41ab7d6e08b3… |
| Group fraud risk assessment (2026-03)risk_register | 2026-05-14 | approved | 1c70de93a4f5821b… |
| Anti-fraud policy v4policy | 2026-05-14 | approved | b85a1209ef34cc77… |
| Supplier due-diligence attestation (pending refresh)third_party_attestation | 2026-05-18 | draft — needs review | 44e9a7c150bd2f6a… |
| Control matrix v2policy | 2026-05-20 | approved | c3a9f102de78bb41… |
| Procurement procedurecontract | 2026-05-20 | draft — needs review | f6017e84ab925c3d… |
| 2026 staff training export (92% complete)training_record | 2026-05-28 | approved | 7d4e51c0f2a38b96… |
| Quarterly ECCTA readiness board review — Q2 2026board_minutes | 2026-06-10 | approved | 3b8f420e9c17da52… |
| All-staff ECCTA anti-fraud briefing — June 2026policy | 2026-06-10 | approved | e10c93d47f5ab081… |
Risk-to-control trace
Each fraud risk is traced to the control evidence relied on, with residual rating and whether it blocks the board pack. This is workflow evidence of how risks map to controls — not a judgement that the controls are adequate.
| Fraud risk | Residual | Board impact | Control evidence |
|---|---|---|---|
| Third-party introducer facilitates fraudulent invoicingProcurement / supplier onboarding · owner Procurement lead (A. Okafor) | Medium | Blocks pack | 2 control evidence items · 1 missing from source register |
| Sales agent misrepresents product to win businessChannel sales · owner Head of Sales (M. Cole) | Low | Clear | 3 control evidence items · all in source register |