What is the difference between conduct and culture?
Culture is the assumptions or beliefs that are common in an organisation and help predict how people will behave. Conduct is the observable behaviours that come from those beliefs.
What is culture and conduct risk? Culture and conduct risk is the uncertainty and potential for loss or failure which is caused by human behaviour or the decisions of employees – and it is a risk which appears to slip through the majority of existing risk management systems.
Conduct regulation is a practice meant to hold banks and financial institutions responsible for their actions. In other words, it represents a set of rules that tell financial firms what is expected and the acceptable behaviour.
Culture underpins conduct and therefore business performance and confidence. That is why to work at a senior level in financial services, you need to pass and continue to meet the conditions of a fitness and propriety assessment. This includes consideration of honesty, integrity and reputation.
A code of conduct is a set of guidelines and principles that outline expected behavior and ethical standards within an organization. It serves as a guide for employees to understand their responsibilities and how to maintain a positive workplace culture.
The conduct risks that the firm is exposed to. Examples of key risks may include insider dealing, conflicts of interest, product design or mis-selling through inappropriate incentive and bonus schemes; The controls in place to monitor and mitigate these risks on an on-going basis.
Conduct risk is a form of business risk that refers to potential misconduct of individuals associated with a firm, including employees, third-party vendors, customers or agents interacting with the firm.
Conduct Risk has been defined by the FCA as, “the risk that firms' behaviours may result in poor outcomes for the consumer”. Conduct Risk takes forward the principle and expected outcomes of Treating a Customer Fairly ('TCF') as prescribed by the FCA.
Risk Culture is defined as institution's norms and attitudes related to risk awareness, risk taking, and risk management. In PwC's globally recognised methodology, the Risk Culture is described by 6 Focus Areas.
Norms are the agreed‐upon expectations and rules by which a culture guides the behavior of its members in any given situation. Of course, norms vary widely across cultural groups.
How does culture influence ethics and conduct?
The most generally accepted concept is that culture is a key determinant of an individual's ethical ideology, which affects an individual's inclination to behave ethically. In other words, culture acts as a guideline in determining whether certain practices are appropriate and acceptable.
Culture is the assumptions or beliefs that are common in an organisation and help predict how people will behave. Conduct is the observable behaviours that come from those beliefs. Some say that culture influences conduct but also conduct influences culture.
The term ethical culture is often used to describe an organisation's values, behaviours, and business practices. It refers to the ways in which people work together within an organisation to ensure that they are fulfilling their responsibilities to each other and their customers by upholding a set of core values.
Often, the Code will also provide a formal expression of the values and culture of an organisation as applied to the everyday workings, ensuring transparency of working practices. The Code can cover anything from the company's dress code and timesheets to how a company expects an employee to act on social media.
- You must act with integrity.
- You must act with due skill, care and diligence.
- You must be open and cooperative with the FCA, the PRA and other regulators.
- You must pay due regard to the interests of customers and treat them fairly.
- You must observe proper standards of market conduct.
One set of five rules is called "Individual Conduct Rules", and the second set of four rules is called the "Senior Manager Conduct Rules." By creating the Code, the FCA aims to: Support the development of the right corporate culture within firms.
All conduct risk frameworks must be incorporated throughout the strategic planning of a business, including its ultimate goals and performance expectations. Without integration, a company can devalue its market position and even restrict its ability to adapt to changes in the business environment.
Rule 1: You must act with integrity. Rule 2: You must act with due skill, care and diligence. Rule 3: You must be open and cooperative with the FCA, the PRA and other regulators. Rule 4: You must pay due regard to the interests of customers and treat them fairly.
- The applicant firm's definition of conduct risk.
- What tools the firm has in place to identify conduct risks.
- First line of defence/ business involvement in conduct risk identification.
- The alignment of conduct risk identification between different business units.
Conduct risk is the threat of financial loss to an organization caused by the poor judgment of managers and employees.
What are the consequences of conduct risk?
Historically, firms have failed to address conduct risk in the way they operate their business and set their strategic objectives. This can lead to regulatory actions and fines but also to reputational damage and customer loss that can impact the business for years.
For the purpose of the PRA assessment, non-conduct risk forecast losses are defined as forecast losses that would not be classified as conduct risk. Gross operational loss net of direct recoveries. Gross loss less direct recoveries.
"Culture is a system of values, beliefs, and behaviors that shapes how things get done within an organization." "Culture risk is created when there's misalignment between an organization's values and leader actions, employee behaviors, or organizational systems."
Firms need to consider: The conduct risks that the firm is exposed to. Examples of key risks may include insider dealing, conflicts of interest, product design or mis-selling through inappropriate incentive and bonus schemes; The controls in place to monitor and mitigate these risks on an on-going basis.
Risk culture is a term describing the values, beliefs, knowledge, attitudes and understanding about risk shared by a group of people with a common purpose.
