Conduct regulators continued to expand their powers and reporting expectations during 2021 and into 2022. Now regulators' 'culture assessment' of firms includes interviews with regulatees' front office staff. Any member of your staff may be what they understand is the everyday workplace meaning of terms such as 'socially purposeful business', 'psychological safety', 'consumer duty', 'safe speak-up', 'inclusive', or 'doing right'. Moving beyond their earlier focus on Senior Manager roles, regulators now listen for 'messages from the engine room', asking staff about how their employer's claimed corporate values play out in practice, and any instances of abusive behaviour ('non-financial misconduct') of any kind. Pre-learned answers will not be acceptable.  

In reality this means your firm's staff now need to be able to discuss, in plain language without compliance jargon, what the Conduct agenda means at a personal level in their own work. How do they recognise 'exemplary conduct' in customer services 'How they routinely care for even the most vulnerable customers'. Show a culture of responsible risk-taking 'Are confident to call out any misconduct they see'.

Though managing conduct never meant simply 'doing Conduct Risk Compliance', various regulators' culture assessments have now brought a new level of ethical scrutiny. Firms need to prepare all staff to join a firm-wide conversation about Conduct - looking beyond the formal Six Conduct Questions, to show an alert awareness of where financial and non-financial misconduct may arise and how to challenge them when they do.      

Attendees at this highly interactive workshop will discover, discuss and practice putting vital elements of ethically 'acceptable and expected behaviour' into action. On completing this session, you will be better equipped to keep your firm ahead of the Conduct regulator's concerns over financial and non-financial misconduct, ensuring that your firm welcomes constructive challenge, thinks diversely and rejects abusive behaviour in any form.

Learning outcomes:

  • The key factors your firm needs to demonstrate at work in practice, to support its claims to an ethical culture 
  • How the regulator uses behavioural science-based tests to assess the ethical quality of your firm's products and marketing propositions
  • Understand what 'social licence' and customer-centric working mean in practice: impacts of pandemic and other vox populi risks; examples such as regulator actions against 'greenwashing'
  • Managing ethical challenges: responding to real-life experience examples where the 'right answer' is not obvious
  • Checking the state of your firm's 'anti-bystanding' initiatives to prevent non-financial misconduct: methods of rating and reporting behaviours that the regulator will monitor (such as speaking up, anti-harrassment, inclusion, cognitive diversity and leadership quality) 
  • Identify, anticipate and manage the grey areas of Conduct risk, where the formal rules fail to provide clear ethical guidance
  • What is meant in practice by 'psychological safety': How to build a continuously learning organisation where constructive challenge is welcomed, where business gains value from a culture of constructive challenge as staff are confident to raise thoughtful questions and co-operate in solving problems
  • Know in plain terms what the Six Conduct Questions really require staff to do in their daily work
  • Improve business resilience and ethical engagement, by harnessing your firm's greatest overlooked asset

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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 resources
  • Other operational risk managers involved with conduct and culture assessments, director and other senior risk governance roles concerned with conduct risk