The subject of organisational conduct is very topical. Time was, that organisations, managers and society turned a blind eye, did not see the impacts, and did not consider the consequences of misconduct. That is no longer the case. Bad conduct within an organisation can have serious consequences for the individual, management and shareholders.  

Conduct became a focus for bank regulators in the wake of the 2008 Financial Crisis.  Before then, “Conduct” was how banks treated their customers, how they behaved in the markets and how they stuck to financial regulations.  Regulatory exams were largely memory tests. 

After the crunch, Regulators realised that the old system didn’t work. Banks were fined again and again and some prosecuted for mis-selling, money laundering, rigging markets, helping politicians steal billions- literally-  and on and on.  Regulators finally realised that people needed integrity and management had to take responsibility and be accountable for what staff did – mis-selling, bullying, whatever the crimes were.  This gave rise to the 2016 Senior management and conduct Regulations in the UK.  Senior management were pinned down as to what they were responsible for, and the testing regime changed.  Banks were asked “how do you ensure good conduct from your staff? Is it how you share values? How you train them? Do you have a sensible, balanced and proportional system for monitoring and sanctioning? Does your system encourage openness, getting people to own up to mistakes, to help improve systems and reward good behaviour -rather that stigmatising all and driving the bad ‘underground’.”

If only the financial sector was the only place where we found bad behaviour.   You don’t need to read much of any newspaper to find problems in Cricket, Tech companies, the Houses of Parliament and pretty much any sector.  The interesting thing now is that banks seem to have turned a corner and they are less in the news for their misdeeds today than in the past. So what has changed?

Following the new bank regulations we have been involved in the root-and-branch change and training initiatives that have changed the culture in Banks.   In response to the new rules, banks changed their internal rules and we started to train senior managers and staff as to how to change culture so that bad conduct wasn’t tolerated at any level, irrespective of how good an individual’s contribution to profits.  

The disciplines involved might seem obvious, but a lack of clarity and adherence to key values lead to a slippery slope: “If I get away with breaking one rule, a second probably won’t hurt.. will it?”.  So what are the keys?

1. Ethical Leadership – As a leader within an organisation, whatever level you are within that organisation, you need to act with integrity and set the example you want others to adopt and follow:
Always act within you designated authority, if you don’t work within your mandate, you can’t expect your teams to do so.
If an issue or incident occurs always escalate, report it don’t let it fester or hide it.  Again, as a leader you want your team to raise issues, concerns and incidents so set the positive norm. Coupled with this, positively encourage and empower staff to speak up if something happens or just doesn’t seem right.


2. Use effective governance – As a leader make sure you understand the policies of your organisation – meaning what they are designed to manage and why they are in place.
Be able to explain relevant policies to staff and show/ train them on the correct procedures to be compliant – As a leader not knowing or bothering to communicate to your team is no defence if they breach the rules.
As a leader always be critical of policies and governance frameworks; that is to say, constantly evaluate against “fit for purpose” and raise suggestions for improvement at the appropriate forums. Following blindly unfit or outdated policies is as bad as non-compliance.


3. People leadership – As a leader of others it is important to set, practise and communicate behaviours and polices with integrity.
Exercise good judgement when recruiting – take second opinions and be very clear with yourself and others why this candidate is right for the role.
Be fair and balanced when conducting performance appraisals, don’t let your personal biases cloud your judgement.
Empower your team to take responsibility for their work – give fair licence to operate and use fair accountability and appropriate sanctions in the event of an issue.
Make sure your staff have the appropriate tools and competency to perform their roles. Make training a progressive achievement, making development part of the team and part of the firm’s culture.

This is all easy to say, but changing hearts and minds is an involved process.

CCT can help at all levels if you are seeking to change the way your people conduct themselves.  Tailored global programmes covering all areas from consulting around values; developing a communication strategy; authoring bespoke training materials; training managers and trainers; and establishing a (pre)disciplinary framework are within our ambit.  Equally short virtual training programme around generic problem areas of conduct are also exactly what we can do.