ANZ's recently released Global Markets Business Review echoed familiar cultural themes reported in the media over the past six years.

The language is familiar. The findings are familiar. And that’s the problem.

Disappointingly, the latest review failed to identify the definitive cultural root causes hindering the necessary shifts to mitigate program execution risk and better manage other non-financial risks.

Diagnosing Symptoms, Not the Disease: Despite the best intentions, the latest report attempts to pinpoint the ‘root causes’ of cultural issues, instead, it describes behaviours and not its drivers. This creates a circular logic: behaviour is both the cause and the effect, with no deeper analysis of what sustains it.

Without isolating definitive root cause, change remains superficial. You can't shift culture by reacting to how it shows up; you must understand why it exists in the first place.

Culture and Risk Culture: A Misleading Distinction: The bank and the report authors treat “culture” and “risk culture” as separate entities, each with its own aspirations, behavioural standards, and metrics.

People don’t experience this artificial distinction; it’s the same culture in which they work to create and protect value. Systems shaping behaviour like purpose and values, performance management, incentives, code of conduct, and leadership expectations cut across both, and this fragmented approach undermines coherence.

The events that led to this report suggest directors and executives lack early warnings on cultural issues, preventing proactive intervention. Existing culture-related methodologies received only minor critique in the report, yet they are also part of the problem. Existing tools are clearly not designed to detect the cultural blockers that matter most - the ones hiding in plain sight in operating rhythms, decision-making forums, or the performance of work in a trading context.

Talent Practices Are Overlooked: Behaviour doesn't manifest in a vacuum. It’s situational and shaped by how people are hired, developed, led, treated, rewarded, and held accountable. The report notes inconsistencies in performance management, consequence frameworks, and remuneration. That’s not just a leadership issue - it’s also a systems issue.

It points to weak oversight over and from the Talent & Culture function to ensure these systems sustain the behaviours and outcomes expected in a heavily regulated business. Equally troubling is the lack of scrutiny from Risk and Internal Audit in testing whether these practices are working as intended.

Any competent culture review must go beyond surface-level behaviour to examine the mechanisms and other forces that create it.

Culture is Hard to Shift, Especially If We Keep Looking in the Wrong Place.

If we want to see real change, the approach must evolve. That means:

Stop confusing symptoms with root causes.
Address artificial distinctions between risk culture and organisational culture.
Interrogate the systems that shape behaviour, not just the people who exhibit it.

Anything less, and we’ll be reading about the same culture themes two years from now.