During 2021 the FCA has promised that firm culture will be on the regulatory agenda. Culture is a difficult concept to measure, so understanding how the FCA might even begin to do this, may well assist you in getting it right and/or being able to articulate what you are doing.


This is what ‘conduct’ is: behaviour. What we seek to achieve here is ‘exemplary behaviour’ and at all times, even when no-one is looking!

In what ways do the FCA expect Senior Management to monitor this?

Ø  By setting an example.

Ø  By providing a ‘safe’ environment in which to speak out.

Ø  By observation.

In what ways can the FCA monitor behaviour?

Ø  Ask for proof of what you have done about something; a Dear CEO letter, for example.

Ø  Ask a member of staff to take them through a process.

Ø  Ask staff what happens if they raise an issue.

Good behaviour is not restricted to the way management treat staff, the way staff treat customers, or the way staff behave during a compliance review; it is reflected in how everybody treats everybody else all the time. Respect is an important part of that.


Behaviours should reflect the culture of an organisation and in turn the culture and values of those within it.

Ø  Are we purposeful?

Ø  Are we socially useful?

Ø  Are we aware of risks as to exercise good governance and resilience?

None of this is intended to obscure the objective to be profitable, to grow or to provide a return on investment for stakeholders, however this is on top of that, but it is also a way of improving performance, profitability, and owner value.

Healthy Culture: How do you demonstrate this?

Ø  Live it; make it business as usual and not just for if a regulator calls.

Ø  Collaborate; make time for the team to confer.

Ø  Report it; demonstrate what goes on in meeting minutes, reviews, and reports.

Put in writing policies and procedures that promote:

Ø  A regular dialogue between staff & management.

Ø  A safe environment to speak up.

Ø  Staff feedback mechanisms.

Importantly, these should not be just lip service. The appearance of the documents, the logo or the length do not matter; what matters is the content, the clarity, and the accessibility of these for all staff.

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