Food Fraud Program Man-
agement—A Maturity Model
“Rome wasn’t built in a day” holds
true for the evolution of a mature food
fraud management system. Evolving
your food fraud program will take time
as you will need to continue to self-educate, educate others, and build
awareness and culture surrounding the
food fraud management components.
To help you develop a strategy or
road map for your food fraud management system, you need to have a
clear picture of what a mature system
could look like. A maturity model is a
nice way to help with understanding
where you are in the evolution of your
program and where you need to go.
The Food Fraud Management System
Maturity Model (Figure 1) illustrates the
stages of maturity in your program and
lists high-level activities that define how
mature your system may be.
When assessing the current state of
your food fraud management system,
you may find that there may be components of your program that fall into
different stages, but how it all comes
together defines the true maturity of
your food fraud management system.
At this stage, the struggle for most
companies is to determine how to meet
determining what is on the horizon.
There are key partnerships that need to be formed when building the food fraud
management system. These functions probably already exist in your organization.
They have the knowledge and own the processes that can help detect food fraud and
ensure relevant information is incorporated into the FFVA.
Food Safety/Quality: Identify a food safety or quality professional who has a working knowledge of food fraud. Supplier quality also will have a deeper knowledge of
the quality health of the supply chain and most likely will serve as your “boots on
the ground,” as they probably visit supplier facilities with some frequency.
Procurement/Purchasing: Engagement from this function will assist by having more
in-depth knowledge of suppliers and information as to where materials are sourced.
They also probably monitor market conditions, changes in pricing, or things that
can impact pricing that can help with monitoring for conditions where a food fraud
vulnerability could increase.
Security/Supply Chain Assurance: Security professionals in the organization have
knowledge of incidents that may involve theft, counterfeiting, and product tampering. They may have additional knowledge of where incidents have occurred in the
past or have knowledge of sensitive or confidential issues that may not be broadly
Trade Compliance: Members of the organization who handle imports and exports
can provide insight to the team on any emerging issues with the transfer of goods
across international borders including through free-trade zones. They probably have
more exposure to import alerts, product detainments, and rejections that are occurring in real time. This knowledge will support any changing vulnerabilities for materials or commodities.
Regulatory Compliance: Regulatory professionals have a working knowledge of any
existing or changing regulations in the markets where goods are being purchased
from or sold. Additionally, their insight into changing regulations in global markets
can provide awareness of any fraud vulnerabilities that may result from changing
This is not an all-inclusive list of the participants but would be a good start as
you develop your program.
Initial FFVA conducted
Program managed by
individual or one SME
Food fraud strategy
not fully developed
Increased inputs to
knowledge on food
Food fraud strategy is
FFVA inputs based on
FFVA is dynamic and
adjusts based on
real-time inputs and
minimum lag time
Risks managed mostly
within the function,
behaviors in support
functions for food
Mature ERM process
for reporting food
Defined Initial Repeatable Optimized Managed
Figure 1. Food Fraud Management System Maturity Model; FFVA: food fraud vulnerability assessment; SME: subject-matter expert; ERM: enterprise risk management