Creating a culture of compliance for the SMCR
What is culture? The Oxford English Dictionary defines it as – ‘The philosophy, practices, and attitudes of an institution, business, or other organisation’.
Generally culture is something that develops naturally over long periods of time shaped as it is by so many factors – societal, demographic, political, social economic etc. It is certainly a very long period of time since the FCA started banging on about culture within financial services institutions – and their expectations in this regard. The FCA’s message has been as unequivocal as it has been longstanding – that it is looking to hold senior management accountable for the embedding of compliant cultures and high ethical and conduct standards. To judge by increases in enforcement levels relating to conduct – one could be forgiven for thinking that this has fallen largely on deaf ears.