Addressing Culture misalignment

Our work centres on helping organisations understand and strengthen relationships between its culture and required outcomes.


Culture Governance

Effectiveness: Review governance charters, information flows, oversight processes/outcomes, and participant experiences related to culture definition, approval, monitoring, and change.

Renewal: Enhance formal governance practices to clarify culture oversight responsibilities, decision-making processes, and information needs/flows for Boards and supporting committees.

Capability Advisory

Consult: Perform objective reviews of existing culture-related activities across core functions to enhance Culture Governance, including risk culture, culture risk, behavioural risk, and the use of culture information in the evaluation of residual risk.

Create: Codevelop and provide coaching support to implement and embed new culture-related capabilities.

Independent Reviews

Assessment: Design and performance of comprehensive assessments to identify and remediate cultural root causes of serious incidents, systemic non-compliance, misconduct and other undesirable outcomes.

Assurance: Programmatic review of culture transformation and remediation programs to identify unintended consequences, mitigate execution risks, and monitor progress.


SELECTED EXPERIENCE SNAPSHOTS

  • Enhancing Board Oversight: Existing risk culture reporting for a banking group failed to provide early warnings of persistent and systemic compliance deficiencies. A refreshed culture governance model enabled HR to take a greater role in supporting Board oversight of culture (incl. risk culture), allowing other functions to develop new highly-specialised and complementary culture-related assessment and reporting capabilities. A new decision-making framework enabled the Board to consistently act on reported culture information.

    Regulatory Remediation: As part of an insurer's risk transformation program, the culture governance model outlined the required information, activities, and capabilities for the P&C, Risk, and Internal Audit functions. This approach helped improve insights while eliminating unproductive efforts.

  • Decisioning Biases: Asia Pacific regulators of a US bank, responding to serious incidents in other jurisdictions, challenged the regional Board to demonstrate that similar incidents were unlikely to occur locally. A new program was designed to uncover unconscious risk-taking by senior leaders, focusing on the tension between reliance on internal controls and managing non-financial risk. Successfully piloted with the Board, the program was rolled out regionally and later adopted globally.

    Assessment Methodologies: In response to a Board challenge on the soundness of risk culture, a comprehensive culture assessment methodology was designed, piloted, and implemented across all jurisdictions for a global investment bank. The two-tier methodology allowed for deeper examination of root causes where necessary, providing a level of rigor that alleviated executive scepticism of the first-of-its-kind methodology.

    Enhancing Assurance: The Chief Auditor for a global private equity/asset manager was concerned that auditors might miss critical information while auditing very different assets across multiple countries. An extension of the audit methodology was developed to explore the influence of culture on the internal control environment, equipping auditors to better understand and report on the necessary actions.

  • AML/CTF: In response to regulatory investigations and statements of claim, comprehensive culture assessments revealed deep-rooted attributes that hindered staff at all levels from consistently demonstrating their compliance obligations. Identified vulnerabilities were able to be systematically addressed through multi-year remediation programs in financial services and licensed gambling organisations.

    Insurance Risk: High declination rates of policies citing long-repealed regulations triggered litigation and costly regulatory-supervised remediation. A comprehensive assessment uncovered multiple root causes, including challenges relating to the influence of parent companies through subsidiary Boards.

    Strategic Risk: The Board of a large banking group was close to deciding on a multi-billion-dollar investment program to digitise banking operations. Directors wanted to understand whether the bank’s culture could support such a transformation, an assessment across executive and senior leader levels revealed entrenched toxic politics and other cultural concerns that pushed residual strategic risk well outside of risk appetite. Consequently, program approval was deferred until cultural attributes of concern could be demonstrably addressed.

    Advice Suitability: New regulations for wealth managers and advisors required them to consistently act in the best interests of clients. However, for some advisors, the entrenched influence of revenue targets meant these regulations could be ignored without consequence. Comprehensive assessments, supported by multi-year assurance activities, helped multiple wealth management companies implement the required changes and satisfy regulators of their embedment.

    Product Quality: A global manufacturer was caught by regulators covering up quality defects, the Board needed to understand the extent of the problem. An assessment across multiple regions isolated the issue to specific countries, enabling the Board to take decisive and targeted action, including increased oversight, until they were satisfied the issues were resolved.