Corporate purpose and culture

Moreover, conduct risks are particularly heightened in a remote working environment and conduct risk management will therefore require special focus and attention to minimise any risk of reputational or operational damage. 

We have extensive experience assessing and managing conduct risk in firms and can review your current risk landscape to evaluate your overall conduct risk, map out key areas of reporting, identify potential gaps and key themes emerging and provide bespoke best practice recommendations to address any issues.

However, the FCA notes that the questions are applicable more widely across all financial sectors as the questions are also incorporated into the FCA's approach to supervision generally. 

These 5 questions (along with the 8 additional questions introduced in 2018/19) form part of the FCA's conduct supervision approach and the FCA expects boards and executive management to investigate these questions in their firms. As such, we have extensive experience in helping firms respond to regulatory information requests regarding the 5 conduct questions, providing insights on peer firms' approach to their conduct and culture programmes and providing practical considerations for firms to support their thinking on this, based on our interactions with clients and regulators.

We can provide advice on how to measure culture, along with best practice guidance on the design and implementation of a consolidated culture and conduct Management Information (MI) dashboard. Developing a full view of both quantitative and qualitative MI, and collating, evaluating, reviewing and responding in a proportionate and sustainable way, can lead to meaningful culture change and ongoing focus on culture. 

We can work with you to develop a conduct and culture dashboard that consolidates quantitative MI with a qualitative overlay, into a single reporting format, that allows senior leaders to better understand the culture of the organisation and more accurately address any concerns through proportionate action plans.

IT is crucial that a firm not only has clearly documented and widely communicated purpose and values statements and codes of conduct, but these messages need to effectively and meaningfully translate to specific roles and responsibilities, targets and objectives at an individual and unit level across the firm. 

We can work with you to design and review your purpose and values statement and code of conduct to ensure that these align with your risk appetite, are sufficiently brought to life for employees across the firm and provide a sustainable, proportionate and pragmatic framework to guide and influence employee behaviours.

Our scenarios go beyond market conduct and business conduct scenarios, they cover topics such as diversity and inclusion, micro aggressions, harassment and speaking up, to help bring company values to life and encourage interactive discussion. We have extensive experience in delivering large scale culture training programmes. Within the core team we have run over 200 training sessions across a number of sectors.

Our experience has shown that participants are able to recall key themes and guidance from scenarios better than lists of dos and don'ts.  Scenario based training acts as dress rehearsals for real situations that they may face, helping them make the right decisions. We can create a safe environment for employees to 'fail' and learn, and allow employees to raise queries in the moment.

Training will typically include practical guidance on how to help Senior Leadership role model appropriate behaviours, establishing the right "tone from the top", promote inclusivity and openness and understand regulatory priorities - including culture and conduct responsibilities under the Senior Manager Regime and advice on the FCA's 5 conduct questions.

We can help ensure senior leadership are able to recognise and manage cultural themes within their own teams. We understand the expectations and nuances of senior management and can help baseline leadership culture relative to the values of the firm.

By asking an organisation’s employees to complete a number of scenario based questions covering common culture themes we are able to provide valuable analysis that can be used to drive overall culture efforts and provide focus for actions and initiatives.

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It can be focused on one business area, one jurisdiction, one employee grade or as a comprehensive exercise done on a sample basis across the whole organisation.

This enables us to provide relevant, practical and actionable recommendations for follow up actions e.g. where a firm's in-practice culture may not be meeting its stated values or broader regulatory expectations. Importantly, such recommendations are made with a view to improvements being proportionate and sustainable, providing firms with a framework for ongoing focus on culture that develops as appropriate in line with - and importantly not behind - any emerging trends or new circumstances. Having conducted a number of health assessments we can draw on peer insights to build tailored recommendations for improving areas that have been prioritised by you.

This provides firms with a framework for ongoing focus on culture that develops as appropriate in line with - and importantly not behind - any emerging trends or new circumstances. 

We have extensive experience in helping firm's design culture frameworks or enhance their existing frameworks so that they have a clear organisational culture and a refreshing culture strategy.