Mar 8, 2022 6 min read

Assessing Ethical Risk - Issue Maturity

A thorough assessment of ethical risk will throw up all sorts of things, some of them familiar, some of them new. After identifying your priorities, you then need to address expectations and resources. This toolkit on issue maturity helps you with that.

issue maturity
Issue maturity helps you to prioritise in relation to expectations for improvement 

What is Issue Maturity?

Issue maturity helps a firm to determine the extent to which it needs to improve on a particular ethical issue. The insurer may prioritise an ethical issue, but then be uncertain about how far it is expected to improve on it. What expectations is it under?

At the same time, every firm works within some form of constraint around resources. They can’t simply dedicate money, time and people to address every priority issue in full. And let's not forget that some ethical issues can take time to resolve.

You can see then that some form of balance needs to be achieved between expectations, resources and resolvability.  Issue maturity helps you work towards the right balance.

What Does Issue Maturity Tell Us?

Issue maturity tells a firm where it is in line with expectations for dealing with an ethical issue, or behind expectations, or ahead of expectations.

Expectations about the extent to which a firm should be addressing something do vary across different ethical risks. Some may be just emerging, with uncertainty as to their full scope and the options for dealing with them. Other ethical issues are fully mature, with lots of information to help assess their scope and depth, and clear examples about how best to deal with them.

For example, take fairness in insurance. It’s an ethical issue that is on the move. Five years ago, most insurers used little more than a checklist for monitoring their ‘treating customers fairly’ obligations to claimants. Now, it is firmly established as part of the ethics of pricing. And over the next five years, there are clear signs that its influence will become even wider.

Another example is discrimination in data and analytics. Discrimination per se is long established as an ethical issue that every firm needs to address. And it is widely acknowledged to be a significant issue around how data is collected and used, and how algorithms are designed and deployed. The challenge many organisations are now facing is how best to reduce and eliminate it within their data and analytics. There’s lots of research being done on how best to do this, so the question has moved from ‘can we?’ to ‘how well are we getting on?’

Four Stages of Issue Maturity

The standard approach to issue maturity is organised around four stages: latent, emerging, consolidating and institutionalised. Here’s what they each mean.


  • there is some public awareness and campaigning around this as an issue;
  • researchers are still exploring it what it means and how to address it;
  • the business community are in a 'wait and see' mode.


  • there is media awareness of the issue, with questions being raised in some political circles;
  • an emerging body of research has helped scope the issue but little data exists around impact and solutions;
  • some firms are tracking the issue and experimenting with how to respond to it.


  • voluntary standards have been developed and adopted across civil society;
  • a clear body of evidence exists around impacts and solutions;
  • business practices are being used to manage the issue across many sectors;
  • there is some litigation around the issue and talk of regulations.


  • the public expects every firm to be addressing this issue;
  • business standards are widely adopted and embedded into sector culture;
  • regulations are being framed or are in place on key aspects of the issue.

These four stages of issue maturity then need to be seen against the context of what's called organisational engagement. I'll explain that next and then show how these two things can be combined.

Four Stages of Organisation Engagement

The four stages of organisational engagement as as follows.


  • there is ad-hoc engagement around this issue, often as a response to an external development;
  • the organisation is learning about the issue, trying to understand more about the issue and its scope.


  • the organisation can established processes for proactive engagement around the issue;
  • little has been done though to incorporate it into plans or management information;
  • its influence on operational decision systems is minimal and personal.


  • ongoing engagement processes are yielding outputs that are now embedded into management information and monitoring;
  • operational decision systems have been adapted to managing the issue and performance objectives are established.


  • the organisation's leaders participate in the engagement processes;
  • the issue is embedded into management and governance processes, with scheduled review and investor reporting;
  • strategic partnerships are in place with relevant groups in civil society, to help deliver change across the sector.  

These are of course very generic descriptions, which some firms may wish to adapt to their own circumstances.

Bringing Maturity and Engagement Together

The maturity of an issue and the organisation's engagement with it can be brought together into a simple matrix.

Now some of you may roll your eyes and talk about 'yet another matrix'. However, whether a matrix is good or bad is not the point here. The two sets of four stages can easily be adapted to fit your firm's risk management approach. I'm using the matrix approach because it has widespread recognition across the members reading this.

Here is a simple matrix covering five ethical priorities, A to E.

An Issue Maturity Matrix for Five Ethical Priorities of a Typical Insurer










Issue B

Issue A





Issue C

Issue D


Issue E










So what does this matrix tell you?

Firstly, there is one ethical issue you're doing well on - issue B. That's because it's above the shaded diagonal line. That shaded line represents where a typical insurer would be expected to be, in terms of those maturity and engagement stages. There is of course nothing wrong with being above that shaded line - I'll come to that in a minute.

Secondly, you'll see that there are two issues on the shaded line - issues A and E. This show that your progress on those two issues is broadly in line with expectations.

And thirdly, there are two issued below the shaded line - issues C and D. This means that your firm is under-performing on those two issues.

Conclusions to be Drawn

The main conclusion to be drawn from this issue maturity matrix is that the firm needs to make progress on issue D. This is an issue that overall, across business, is at the institutionalised stage, while within this insurer, it's still at the developing stage. That represents two stages of under-engagement.  That's the issue that should receive most attention.

Issue C also needs some attention as well. Remember that these are not either/or issues. They're the issues that this insurer has identified as priorities for it to address. So any issue below the shaded diagonal needs addressing to some degree.

So what about issue B? It's above the shaded diagonal, which means that the firm's engagement with it is more advanced than other firms. Remember that that it a positive, not a problem. It's likely arisen because of particular circumstances relevant to this firm, or the personal interest of one of its executives.

Anything above the shaded diagonal are opportunities for the firm to show leadership across the sector on that issue. However, this needs to be seen in balance with issues below the shaded diagonal. If the firm has one issue above the diagonal and lots of issues below the diagonal, that leadership should be totally focussed on dealing with those issues below the diagonal. Context matters.

A Word of Warning

There's one important warning I should raise about how this matrix is used. It is that decisions around where a firm sits on that engagement axis, and where that issue lies on the maturity axis, need to be handled carefully. It would be all too easy for the firm to think that its engagement is more developed than is the case, or that the maturity of an issue is less than it is in reality.

To be useful as a tool, there needs to be at least an independent person involved in weighing those stages of engagement and maturity. Even better, the process should be conducted with civil society groups specialising in those issues. What is important is that some form of independent and informed voice is brought in. It's the first thing I look for when reviewing a matrix like this. You may want to check out this other toolkit on ethical dialogue...

Evaluating Ethical Dialogue
Insurers are increasingly engaging with external audiences on topics of shared ethical concern. This toolkit helps you evaluate how good your dialogue process is.

Putting this Matrix to Use

The reason some insurers haven't used an issue maturity matrix before is usually because the risks they've been reviewing have been clearer and more certain in scope and development. That's not always the case with ethical issues, and in particular with some data ethics risks.

The issue maturity matrix allows a firm to manage the uncertainty that can be associated with some ethical issues. And it allows them to incorporate feedback from civil society groups on a particular issue, something that most firms' risk management processes haven't done before.

Duncan Minty
Duncan Minty
Duncan has been researching and writing about ethics in insurance for over 20 years. As a Chartered Insurance Practitioner, he combines market knowledge with a strong and independent radar on ethics.
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