Ethics and compliance culture survey for a significant global bank

The bank had a long history of commitment to high ethical standards, corporate values and business practices. The bank’s culture was seen by management as collaborative and supportive, especially in comparison to peers.

The global Board had become aware of a number of instances of behaviours inconsistent with the bank’s espoused values. While recognising that in a large organisation there would inevitably be some individual bad actors, the Board wanted to understand why these behaviours hadn’t been challenged and reported sooner.

We were commissioned to conduct a global survey of the bank’s culture, behaviours and alignment with the espoused values.

We selected a team combining investment banking, business ethics and organisational psychology competences. We designed a robust, evidence-based programme of work to assess key elements of the bank culture and behavioural drivers across its business units and global locations.

Our interventions included document reviews, web-based research, in-person interviews with senior managers and horizontal and vertical segmented focus groups with a wider group of staff. We used carefully constructed agendas to build trust and explore culture and behaviour within the business units from a number of different perspectives. Comments were recorded verbatim in many cases.

The raw data was analysed using quantitative data analysis tools to identify and validate (or invalidate) potential themes, supported by related quotes and segmented by business unit, geography, seniority and tenure.

Our robust analysis provided an objective and supportable set of findings that were persuasive to a management team that was very data-driven in its approach. Building on this confidence in the results, we were able to provide a pragmatic set of recommendations to address underlying causes of the observed behaviours, rather than addressing the symptoms. The bank asked our team to provide a follow up review, and to provide a direct briefing to regulators to reflect the serious and focused approach of the management team.

John Higgins

John Higgins

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