Q: Where should I focus attention to improve culture in my business?
A: Every culture is likely to be different, but managing the drivers of behaviours in any company is key.
The expansion of the Senior Managers and Certification Regime to all regulated advice companies links closely to organisational culture.
Wise companies are therefore taking the opportunity to review and assess their culture as an essential part of SMCR implementation.
The ongoing focus of the SMCR includes the fitness and propriety of senior managers and the extension of conduct rules to all but ancillary staff.
Both form the basis of a healthy internal culture.
So, as you are putting measures in place to implement and keep on top of SMCR compliance, you can also consider the following areas to positively impact the culture of your business.
Senior managers have responsibility for embedding the SMCR into a company’s culture, ensuring it is part of business as usual processes.
They can achieve this by being a role model, creating a culture of accountability through an effective governance and conduct risk framework, and ensuring the availability of appropriate management information to monitor and measure the influence of organisational culture on customer outcomes.
Middle-managers often have the biggest influence on the behaviour of those they are responsible for.
So failure to gain their buy-in can dilute and disrupt efforts to improve a company’s culture.
With middle-managers falling under the certification regime, it brings a renewed focus on conduct.
When staff in your business know what your company stands for, what they are all working towards and how that can be achieved in practice, it provides a roadmap for good corporate culture.
Map your values to the conduct rules to help make sure your values support SMCR.
Make sure that your company’s reward and incentive schemes include a requirement to follow and embody the conduct rules.
Make adherence to the conduct rules part of your recruitment policy and practices, helping you employ the right people who share your company’s values and purpose.
A culture and conduct risk assessment is a great way to check up on the key drivers of good culture, and to make sure SMCR is properly embedded and supported in your business.
It is important to remember that there is no off-the-shelf approach to tackling this. Your company is unique.
Having a good culture does not just help satisfy the Financial Conduct Authority – it is the backbone of improving customer outcomes.
And when customers are taken care of and you are on top of your regulatory responsibilities, you are setting yourself up for success.
Lorraine Mouat is an associate director at TCC
