Transforming Culture and Conduct

Watch out for the unintended consequences

As with any regulatory change programme, some level of disruption in its wake is a given. But post-implementation, you should be paying attention to any significant unintended consequences that might start to emerge. If managed carefully, it’s unlikely you’ll see any negative impacts.


Micro-management		Over-engineering
You need your staff to take their obligations seriously. But with the increased scrutiny and accountability of SMCR, has it created a culture of fear? Are senior managers more reluctant to take a step back? This is something the banking sector saw in the early days of the regime, so don’t let it become an issue for your business by focusing on fostering a healthy culture of openness and providing adequate training for managers.		Naturally, you’ll want your processes to be as compliant as possible. But if in response to SMCR you added in extra layers of monitoring and reporting, you could find yourself bogged down by bureaucracy. Not only will this increase compliance costs, but productivity will drop too. Our advice? Periodically review any process changes you made, assessing if and how they’ve affected your teams output to make sure your original approach was proportional.


Barriers to innovation
While increased risk accountability and the tightening of risk controls is rarely a bad thing, excessive nervousness that stalls innovation will only harm customers in the long run. Now is the time to review any changes to procedures and, if needed, provide more clarity around how managers can take a more balanced approach.