From complaints data to T&C records, there’s a wealth of valuable data circulating around your business. More often than not, this is already being harnessed to inform conduct risk MI. That’s nothing new – the FCA is, after all, a conduct regulator and most businesses are pretty used to collecting this sort of MI as part and parcel of their risk management framework.
But what many firms we speak to don’t realise is that much of the information they’ve already collected is potentially useful for their culture change programmes, particularly when combined with more qualitative data you can get from sources like employee insights and systems intelligence as part of a holistic culture assessment.
In fact, less than half of businesses are currently using their existing business MI to assess culture.
In our experience, this is usually because the MI isn’t being interrogated through a culture lens. By that we mean that a firm’s thinking might be stuck in ‘conduct risk’ mode, monitoring specific data to defend against exceptional cases of misconduct. While this is necessary work, in recent years the FCA’s focus has shifted towards the broader concept of culture — the thing that, ultimately, embeds good behaviour and conduct as the norm.
Here at TCC, we encourage all our clients to think in this way too. Re-examining your conduct risk MI through a culture lens can expose a whole host of cultural indicators, giving senior managers what they need to make more informed and effective decisions on culture.
So, where are these cultural indicators lurking?
There’s many sources you can choose from, most of which you’ll already be utilising for other purposes. These include: