Case study: Culture & conduct risk assessment
Connecting the dots: tackling conduct risk with a better culture
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A vertically integrated firm was on the acquisition trail and growing quickly. But with two material acquisitions under its belt, our client had concerns about some cultural practices in each firm which were making it difficult to manage conduct risk effectively. As part of the embedding process, it was keen to understand each firm's unique culture and how it could create a healthier, more consistent one post-acquisition. As the only compliance experts who link culture and compliance to drive better outcomes, our client knew we had the expertise they needed.
We know FCA regulation inside out, so we knew that if our client wanted to meet expectations, they'd not only have to create cultural change but track and evidence it too.
We started by reviewing the culture of each firm to determine strengths and weaknesses, the top down controls in play, and how culture manifested itself in practice. This included a desk-based review, a cultural survey, staff interviews and an in-depth look at customer outcomes. After that, we laid out a clear action plan for improvement, including:
- Creation of overarching culture policies and procedures
- Training plan for all levels in the organisation
- Enhanced MI to report on cultural indicators, enabling effective measurement and reporting on cultural change and the impact on customer outcomes.
The client was fully committed to driving cultural change but recognised that it had to convince hearts and minds, so that it wasn't perceived as a token effort. Thanks to our focused approach and the successful delivery of our review, our client asked us to provide ongoing support and to oversee the implementation of our recommendations. We ensured that it became an ongoing, evolving and self-fulfilling initiative rather than a single piece of programme change. As a result, our client saw a vastly improved and aligned culture across all acquired firms, better customer service levels and outcomes.
The TCC difference
- We connected the dots between culture and compliance, making it easier for our client to manage conduct risk and ensure the right outcomes for their customers during a hectic time. Ultimately, they'll reap the commercial rewards further down the line.
- Effective cultural change can be a tough nut to crack. We keep things simple by setting out a clear action plan and taking a focused approach so our client only had to focus on actions that would make a tangible difference.