Auditing your Culture: How to exceed the FCA’s expectations

From 2017, banks must measure their culture, to prove to the regulator how they are changing it for the better.  As yet, there is no consensus on how to go about this new form of reporting; in fact, there are as many prototype dashboard designs as there are banks working on them.  This intensive workshop provides a unique first opportunity for attendees to compare their own work in progress with other banks’ alternate approaches.

The regulator expects culture audits to inform and support other improvements: earlier detection of wrongdoing; ever clearer commitments to “individual morality and responsibility” under SMCR; and more “salient and vivid” (that is, socially painful) punishments.

This session directly answers enquiries from the many individuals charged with measuring their bank’s culture: How to identify and track culture credibly; which indicators are most useful to include on a culture dashboard; and what sources inform the regulator’s thinking.

As well as attending this session, members are invited to submit in advance and in confidence any scenarios, key indicator sets and dashboard prototypes for confidential preview and discussion.

Senior lead managers for culture measurement have been asking whether their own current approaches are valid and worthwhile, and whether the regulator is likely to approve them when first reported.  This full-day workshop directly addresses these concerns, providing an overview of the FCA’s approach to culture, favoured methods among other banks and in other industries, and the latest techniques in assembling effective indicator sets.

By attending this session you will:

  • Understand the FCA’s view of what constitutes acceptable and unacceptable cultures, in the Boardroom, in business lines, and in compliance functions;
  • See practical examples of indicators used to measure and incentivise a culture of good conduct and compliance;
  • Find new forms of practical response to the question of “what good behaviour looks like”;
  • Identify significant patterns of preferred and prohibited behaviour;
  • Be better equipped to assemble a cultural measurement tool and to appraise the value of culture and compliance initiatives.


Who will benefit

Chief Risk Officers; Conduct and Culture function leaders, programme and project managers; General Counsel, Corporate and Regulatory Affairs specialists; Human Resource and other Operational Risk managers involved with Conduct and Culture assessments; Director and other senior Risk Governance roles concerned with Conduct Risk.

Session 1: How we came to be here

Lessons from Conduct and other recent culture-related enforcements
Why a report of “full compliance” is a fiction; what should replace this
The regulator’s various strategies to address the (impossible) task
Where past regulatory initiatives failed

  • Structural and cultural drivers of non-compliance
  • What’s fundamentally different about the latest approach?


Session 2:

‘Behavioural regulation’ and key components of culture
The regulator’s latest outlook on compliance:

  • The determining factors: incentives, biases, morality and social proof
  • How to drive change


Session 3:

Various members’ approaches (anonymously shown):

  • Conduct and Culture assessment
  • Using culture measures to build and protect value


Reporting dashboards:

  • Some key components
  • How does my bank’s culture measure project compare with others’ initiatives?
  • How does my bank’s culture compare with others’ cultures?


Session 4:

Other measurement initiatives:

  • Newly identified factors and indicators
  • Tools and techniques from beyond the sector
  • Conclusion and outlook

Registration: 09:00
Start: 09:30
Close: 17:00

Lunch will be served and there will be two 15 minute breaks (mid-morning, mid-afternoon).

*  Please note that the programme sequence and/or subject matter may differ from what is presented herein; the programme is constantly being updated to embrace new ideas and developments – as they evolve.

Trainers use a blend of presentational methods in order to assist in a delegate’s understanding of the workshop content; where applicable and possible, the workshop is enhanced through the use of group exercises, role play, and case studies.

Dr Roger Miles

Dr Roger Miles researches behavioural risk and the impacts of conduct regulation. He counsels Boards on governance of human risk factors and related uncertainty, and delivers bespoke risk workshops for leadership groups in commerce and the professions, uniformed services, government and NGOs. He teaches risk-related psychology at graduate schools including Cambridge University and the UK Defence Academy.


He co-edits the LSE’s annual Behavioural Economics Guides and publishes commentaries through Reuters and Berkeley Research, and best practice guidance through professional bodies including the BBA, ABI, GARP and IOR. His latest book is a plain-language guide for managers, Conduct Risk Management: A Behavioural Approach, published in 2017; available from the BBA at a special discount to members (contact Philip Allen, BBA).

Take this workshop in-house

If you have five or more delegates who wish to attend this course, it may be more cost effective to run it in-company. To find out more about in-company training, please contact Philip Allen Director of Learning on 0207 216 8843 or