
The Tough Trust Method
Fraud starts in dark corners.
Tough Trust shines the light.
A Board-level framework for the Economic Crime and Corporate Transparency Act 2023 – treating the prevention of fraud not as a tick-box exercise, but as a leadership challenge.
Welcome
A welcome from Pete Ashby
Keeps playing as you explore the site.
The unifying word
There's one word behind everything Pete does – and everything the Method stands for: trust.
Not the soft, assumed kind that quietly looks the other way – but trust that is tough enough to ask the hard questions, and honest enough to hear the answers. Trust that holds under pressure, because it is built in the small decisions, every single day.
The new legal reality
£36m+
annual turnover
250+
employees
Organisations that turn over more than £36 million a year, and have more than 250 employees, are now required to comply with the Failure to Prevent Fraud provisions of the Economic Crime and Corporate Transparency Act 2023.
This means that Boards have to demonstrate a "top level commitment" to put in place "reasonable procedures" to prevent fraud.
If you don't, and fraud takes place that was justified as benefitting the organisation, the organisation could be held criminally liable.

Pete with one of the 200+ groups he has worked with in the Vicars' Hall, Windsor Castle.
A leadership challenge
Not a job for the auditors.
Instead of just asking your auditors to review internal financial procedures, this is a real leadership challenge for the whole Board and the Executive team – to ensure that your internal culture is founded on the two key principles that sit at the heart of any effective anti-fraud strategy: truthfulness and transparency.
They are central to the Tough Trust Method, as this website shows – with its draft commitments to stopping fraud and dishonesty from ever gaining a foothold in your organisation.
The Tough Trust Method
Ten Board-level commitments.
A practical framework any Board can adopt – each point earned the hard way, and rewritten in daylight as the organisation learns.
We assume the best – and verify the rest
Truth comes first, and it travels fastest
Whistleblowers are respected and championed
No secret zones
We run unscheduled deep-dives
Wilful blindness is actively discouraged
Mavericks do not hijack the culture
We link high trust to high performance
We practise what we preach
This Commitment evolves
Work with Pete
Three ways to engage
Initial conversations are always off the record.

