Opportunism

Establish and maintain processes where all policy violations, including those perceived as minor or low-impact, are addressed consistently, proportionately, and promptly. By reinforcing that even small infractions matter, organizations deter boundary testing behaviors and reduce the risk of escalation into more serious incidents.

Implementation Approaches

• Develop clear disciplinary guidelines that outline expected consequences for different categories of violations, ensuring minor infractions are not overlooked.
• Empower first-line supervisors and managers with authority and tools to address minor violations at the earliest opportunity through corrective conversations, formal warnings, or minor sanctions as appropriate.
• Track policy violations centrally, including minor incidents, to identify repeat offenders or emerging behavioral patterns across time.
• Communicate the rationale for enforcement to the workforce, framing minor violation enforcement as a measure to protect operational integrity rather than bureaucratic punishment.
• Conduct periodic reviews of enforcement actions to ensure consistency across departments, teams, and levels of seniority, minimizing perceptions of favoritism or uneven discipline.

Operational Principles

• Proportionality: Responses to minor violations should be appropriate to the severity but still reinforce the boundary.
• Visibility: Enforcement actions should be visible enough to deter others, without unnecessarily shaming or alienating individuals.
• Predictability: Personnel should understand that violations will predictably result in consequences, eliminating ambiguity or assumptions of tolerance.
• Escalation Readiness: Organizations should be prepared to escalate interventions for individuals who demonstrate patterns of repeated minor violations.

Offering mental health support and conflict resolution programs to
help employees identify and report manipulative behavior in the
workplace

A structured program, including a helpline or other reporting mechanism, designed to assist employees who feel vulnerable, whether due to personal issues, coercion, or extortion. This process allows employees to confidentially raise concerns with trusted teams, such as Human Resources or other qualified professionals. In some cases, it may be appropriate to discreetly share this information with trusted individuals within the Insider Risk Management Program to help prevent and detect insider threats while also providing necessary support to the employee.

Mandatory security awareness training for employees can help them to recognize a range of cyber attacks that they can play a part in preventing or detecting. This can include topics such as phishing, social engineering, and data classification, amongst others.

An Acceptable Use Policy (AUP) is a set of rules outlining acceptable and unacceptable uses of an organization's computer systems and network resources. It acts as a deterrent to prevent employees from conducting illegitimate activities by clearly defining expectations, reinforcing legal and ethical standards, establishing accountability, specifying consequences for violations, and promoting education and awareness about security risks.

Provide a process for all staff members to report concerning and/or suspicious behaviour to the organization's security team for review. An internal whistleblowing process should take into consideration the privacy of the reporter and the subject(s) of the report, with specific regard to safeguarding against reprisals against reporters.

Certain infringements can be prevented by prohibiting certain devices from being brought on-site.

Regulation Awareness Training equips staff with the knowledge and understanding required to comply with legal, regulatory, and policy obligations relevant to their roles. This includes, but is not limited to, export controls, international sanctions, anti-bribery laws, conflict-of-interest rules, antitrust regulations, and data protection requirements.

The training should be customized according to the specific risks of different roles within the organization, ensuring that employees in high-risk areas—such as legal, procurement, sales, finance, engineering, and senior management—receive in-depth education on how to recognize and avoid behaviors that could lead to regulatory violations. Scenarios that could result in inadvertent or intentional breaches should be addressed, alongside practical advice on how to report concerns and escalate issues.

To accommodate varying learning styles and operational needs, Regulation Awareness Training can be delivered through multiple formats:

• eLearning Modules: For general staff, to provide flexible, scalable training on compliance topics, which can be completed at the employee's convenience.
• Instructor-led Sessions: For higher-risk roles or senior management, where more interactive, in-depth training may be necessary to address complex regulatory requirements and nuanced decision-making.
• Scenario-based Workshops: To reinforce learning with real-world examples and role-playing exercises that help employees internalize regulatory concepts.

By fostering a culture of compliance and accountability, Regulation Awareness Training helps minimize the risk of breaches, whether intentional or accidental, and strengthens the organization’s ability to identify, prevent, and respond to regulatory infringements.

Establish and maintain formal, well-communicated pathways for personnel to request resources, report deficiencies, or propose operational improvements. By providing structured mechanisms to meet legitimate needs, organizations reduce the likelihood that subjects will bypass policy controls through opportunistic or unauthorized actions.

Implementation Approaches

• Create clear, accessible request processes for technology needs, system enhancements, and operational support requirements.
• Ensure personnel understand how to escalate unmet needs when standard processes are insufficient, including rapid escalation pathways for operational environments.
• Maintain service-level agreements (SLAs) or expected response times to requests, ensuring perceived barriers or delays do not incentivize unofficial action.
• Integrate feedback mechanisms that allow users to suggest improvements or report resource shortfalls anonymously or through designated representatives.
• Publicize successful examples where formal channels resulted in legitimate needs being met, reinforcing the effectiveness and trustworthiness of the system.

Operational Principles

• Responsiveness: Requests must be acknowledged and processed promptly to prevent frustration and informal workarounds.
• Transparency: Personnel should be informed about request status and outcomes to maintain trust in the process.
• Accountability: Ownership for handling requests must be clearly assigned to responsible teams or individuals.
• Cultural Integration: Leaders and supervisors should reinforce the use of formal channels and discourage unsanctioned self-remediation efforts.

A scheduled, systematic audit of organizational assets to verify that all hardware, software, and network infrastructure aligns with approved inventories and configuration baselines. The audit is designed to detect unauthorized, unapproved, or misconfigured assets that may have been introduced opportunistically by subjects circumventing standard processes.

Detection Methods

• Conduct periodic formal asset discovery audits using network scanning tools, endpoint management platforms, and manual verification processes.
• Reconcile discovered assets against authoritative asset management databases (e.g., CMDB, inventory systems).
• Inspect critical operational areas physically to identify unauthorized devices such as rogue wireless access points, unsanctioned satellite terminals, or personally procured IT hardware.
• Require supporting documentation (e.g., procurement records, change approvals) for all assets found during audits.
• Audit virtual infrastructure and cloud accounts to detect unapproved services, instances, or network configurations introduced outside formal governance.

Indicators

• Assets detected during the audit that are absent from official asset registries.
• Devices operating without appropriate configuration management, endpoint security tooling, or monitoring integration.
• Physical or virtual infrastructure deployed without associated change control, procurement, or authorization records.
• Wireless networks or external connections operating without approved designations or safeguards.

Financial auditing independently reviews financial records to ensure accuracy and compliance, detecting irregularities and evaluating internal controls. It protects against abuse by identifying fraud and deterring dishonest behavior through increased accountability.

Monitor and analyze minor policy violations over time to detect emerging behavioral patterns that may indicate boundary testing, behavioural drift, or preparation for more serious misconduct. Isolated minor infringements may appear benign, but repeated or clustered incidents can signal a developing threat trajectory.

Detection Methods

• Maintain centralized logging of all recorded policy violations, including low-severity infractions, within case management, HR, or security systems.
• Implement analytical tools or workflows that flag individuals with multiple minor violations within defined timeframes (e.g., repeated unauthorized device use, bypassing security protocols, small unauthorized disclosures).
• Correlate minor violation data with other risk indicators such as unauthorized access attempts, changes in behavioral baselines, or indicators of disgruntlement.
• Analyze patterns across teams, units, or operational areas to detect systemic issues or cultural tolerance of rule-breaking behaviors.
• Conduct periodic behavioral risk reviews that explicitly include minor infractions as part of insider threat monitoring programs.
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Indicators

• Subjects accumulating multiple low-level infractions without corresponding corrective action or behavioral improvement.
• Increased frequency or severity of minor violations over time, suggesting desensitization or emboldenment.
• Violations spanning multiple domains (e.g., IT security, operational protocols, HR policy), indicating generalized disregard for rules.
• Evidence that minor violations are clustered around operational pressures, major organizational changes, or periods of reduced oversight.