“Like a gentle breeze, culture may be hard to see, but you can feel it.”
— William C Dudley, attributed in Hanrahan, Pamela F, “On Compliance” , June 26, 2018
Culture: the ‘vibe’ of compliance
Given that Compliance is a discipline that’s often accused of embracing Excel at the cost of effectiveness, there’s no surprise that Compliance Managers often struggle to quantify, measure and compare critical aspects of the businesses they seek to guide. For all the promises of better systems, and more systemic analysis, most compliance functions are isolated, impotent and ill-equipped to manage – or even effectively oversee – regulatory risks and the acts and omissions of the business’ representatives.
This yawning chasm between ‘promise’ and ‘performance’ of Compliance was starkly highlighted by the Royal Commission. While a range of compliance failures were highlighted, the Commissioner thankfully identified management, conflicts and ‘culture’ as the underlying causes of these failures.
Unfortunately, as is often the way, the Compliance functions of many licensees have been charged with responsibility. If our clients are any indication, they’ll do an incredible job in implementing the Commissioner’s recommendations and reconciling ethics, stricter regulatory requirements and commercial necessities.
They may find, however, that ‘culture’ – the beating heart of their business – is protean, unmanageable and almost impossible to convincingly define. Trying to do so, in the absence of relevant information and comparative data, makes a difficult task impossible.
Read ‘on compliance’
Compare and contrast
“Measure what is measurable, and make measurable what is not so”
— Galileo Galilei
While the capability and experience of our team has underpinned our success, Assured Support is a data driven business that has always believed in the value of measurement, comparison and contrast. In fact, these values (and contextual analysis) are at the core of all our review methodologies. Detailed analysis, comparison and benchmarking is provided in our Advice Assurance and Licensee reviews.
We’ve written about our risk and conduct approach previously. We’ve also repeatedly emphasised the value of ‘small data’ – local, specific and integrated information – and written about our belief that misconduct is more frequently the result of environment than personal preferences.
We don’t intend to labour these points in this article, nor do we intend to offer general prescriptions for specific problems but we want to help you understand whether, and to what extent, you compare with your peers on ‘culture’.
The following diagnostic, extracted from our broader methodology, may assist you to understand some of the ‘measures, processes and procedures’ that we think are credible indicators of a business’ culture. Clearly, an effective assessment requires far more analysis and introspection than the diagnostic allows, but it might help you focus your resources and prioritise your activities.
Culture: Eight indicators
“Now more than ever, firms need to be thinking carefully about culture as a driver of risk and performance”
— Elizabeth Arzadon
A basic cultural diagnostic follows. If it’s helpful, please use it. If it’s not helpful to you, don’t.
The survey is anonymous, but if you complete it you’ll be provided with the aggregated results against which you can compare your own business.