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This full-day workshop answers these concerns, providing a uniquely informed insight into the FCA's practical approach to assessing culture within its conduct assessments; the most effective methods used in other regulated financial firms; lessons from comparable experiences in other regulated sectors; and which of the new assessment tools and techniques deliver greatest business value in use.

2022 sees conduct regulators internationally adding "culture assessment" activities to their existing conduct assessments. "What do you understand to be the purpose of your firm"?, regulators in some jurisdictions will now directly discuss with your front-line colleagues. The UK's conduct and prudential regulators expect each financial firm to at least show how it is involving every individual colleague in managing a socially responsible, inclusive culture and how you will produce a measured, qualified report on your firm-wide progress with this.

The event of Covid-19 and persistent public unease over governance have prompted conduct regulators globally to question firms more closely as to culture and purpose - not only assessing SMCR-attested business leaders but some now interviewing line managers and other colleagues, weighing up 'messages from the engine room'. Under this assessment, a wider selection of colleagues across your firm may now be asked about 'the way we do things here' and how far they see their employer creating the psychological safety needed to support a resilient, positive culture. Your firm is expected to demonstrate exemplary conduct rather than merely mitigating regulated conduct risk.

Attendees at this session will discover what to expect as the regulator assesses culture - since many practical details of the new approach are still emerging. They will also discover how to derive business benefit from the new audit techniques. This includes identifying and quantifying elements of business value that previously had fallen outside the scope of conduct reporting such as colleague recruitment and retention, quality of attention to Consumer Duty, early detection of "non-financial misconduct" and improved problem-solving by applying "cognitive diversity" to deepen team engagement.

At this intensive workshop, member firms will have first sight of best-practice examples of culture initiatives and reports from across the regulated financial sector worldwide. You can also compare your firm's own work-in-progress culture initiative with other firms' approaches. Responding to requests from member firms' culture lead managers, we look at how to identify, track and report on culture credibly, five vital indicators to include in your internal culture assessment and which scientific research sources are shaping the regulator's latest thinking.

We also invite members attending this session to submit privately in advance any scenarios, key indicators and report prototypes for confidential response and discussion.

Learning outcomes:

  • Understand the Financial Conduct Authority (FCA)'s view of where your firm's culture appears on an 'acceptable to unacceptable' scale, including in your boardroom, business lines and compliance functions
  • See working examples of measures used to incentivise a positive risk culture and exemplary behaviour
  • How Covid-19 and its aftermath are changing the definition of 'acceptable' conduct, Consumer Duty, care of vulnerable customers and development of future-proof products
  • Align your firm's culture initiatives with relevant conduct reporting frameworks including SMCR, COCON, Six Conduct Questions, and Purposeful Culture
  • Ways to keep ahead of regulators? fast-evolving definition of 'what good behaviour looks like'
  • Identify significant patterns of 'exemplary' or 'unacceptable' behaviour and respond appropriately
  • How to identify and use only those culture assessment tools that add measurable business value

 

Dr Roger Miles

Dr Roger Miles

Financial practitioner turned specialist researcher in the field of regulated Conduct

Dr Roger Miles researches human-factor risks among regulated financial providers worldwide, helping steer their responses to new Conduct regulations, ...

Dr Roger Miles researches human-factor risks among regulated financial providers worldwide, helping steer their responses to new Conduct regulations, Culture Audits and capital charges against Reputation Risk. He convenes knowledge sharing groups of senior executives including forums at UK Finance, whose Conduct and Culture Academy he co-founded in 2017.

Following audit practice with PwC he advised the Boards of large publicly listed companies in the UK, EU and US as a partner in investor relations firm Georgeson & Co. He was Director of Communications and Enterprises for the BBA (under Sir Brian Pitman), UK corporate affairs lead at FBE in Brussels, and later a Head of Risk Communications in HM Civil Service, before giving all that up to requalify as a risk psychologist and university lecturer.

He frequently works by invitation directly with firms? senior leaders on in-house initiatives to develop their frameworks for conduct risk and culture.

With research among more than 400 firms participating in UK Finance Conduct sessions since 2016, he has amassed a unique exemplar body of conduct programmes, reporting designs, indicators and definitions. He welcomes sharing these insights with UK Finance attendees, to inform discussions of ?exemplary practice? in measurement and reporting on conduct, culture and reputation.

Session attendees consistently rate him 5* / 95-100% for ?expertise?, ?ease of understanding?, ?open and engaging?, and ?enjoyable experience?. Each year he leads small-group interactive workshops for more than 1000 attested Senior Managers in financial firms; since 2010 he has taught one-to-one or in small groups, 10,000+ leaders and divisional managers in financial, professional and government service.

His research often uses language analytics and specialist 'sensitive topic research? techniques to identify previously unvoiced concerns. These findings, unique to each firm, guide the design of the firm's framework of human-factor risk indicators and reports, encouraging the start of productive ?conduct conversations? at all levels, embedding spontaneous best practice in risk reporting.

He lectures as a visiting SME at business schools in Cambridge and London, and at UK Defence Academy; and moderates cross-industry working groups for Board appointees, Compliance, Legal and HR professionals.

His published work includes the financial sector's popular handbook Conduct Risk Management: A behavioural approach (2017) and Culture Audit: Reporting on behaviour to conduct regulators (2021), which includes chapters co-authored with senior regulators in the UK, EU, US and APAC. (Both titles available to UK Finance session attendees at a special discount). He co-edits the Encyclopaedia of Key Psychology Concepts for the London School of Economics annual Behavioral Economics Guides and is a contributing editor at Thomson Reuters Regulatory Intelligence.

In 2006-7, using live observation and narrative research, he analysed how banks were ?gaming? their public reporting on regulatory capital. King's College London awarded him a PhD for this work, whose theory was validated abruptly when global financial markets crashed in 2008. In 2010 he accurately predicted the change of financial regime to ?behaviour-based regulation?; the UK's Conduct regime launched in 2013 and included core principles he had earlier identified.

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  • 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