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What Does Good Risk Culture Actually Look Like?

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What Does Good Risk Culture Actually Look Like?

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At RiskMinds International 2015, Rafael Gomes presented "What Does Good Risk Culture Actually Look Like?" and addressed risk culture and conduct in practice. Get more information from Rafael’s blog post, which describes how financial services can recognize, measure, and communicate good risk culture: http://bit.ly/1RFBrzF

At RiskMinds International 2015, Rafael Gomes presented "What Does Good Risk Culture Actually Look Like?" and addressed risk culture and conduct in practice. Get more information from Rafael’s blog post, which describes how financial services can recognize, measure, and communicate good risk culture: http://bit.ly/1RFBrzF

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What Does Good Risk Culture Actually Look Like?

  1. 1. Risk Culture and Conduct in Practice: What does ‘good culture’ look like? Rafael Gomes Amsterdam, RiskMinds 2015
  2. 2. Good ‘Corporate Governance’ In practice, our understanding of what comprises ‘good conduct and culture’ have grown exponentially Copyright © 2015 Accenture All rights reserved. 2 1990s 2000s 2015 2010s ‘Treating Customers Fairly’ • Personal Accountability • Product Governance • Measuring Culture • Speaking Up (Whistle- blowing) • Vulnerable Customers • Complaints • Social Media • Conflicts of Interest • Digital Channels • Market Conduct • Conduct Risk • Reputational Risk • Risk Culture • Market Conduct • Mis-selling and Suitability • Complaints
  3. 3. How we perceive culture is often distorted by popular myths Myth Reality • Behaviours develop in networks, not only in individuals, and culture has to be worked. • Past misconduct has sometimes been in accordance with policies, norms or the business model. • Non-financial factors have a greater and more sustainable effect on behaviour of high earners. • Cultural issues vary across financial services. For example, mis-selling is not generally a trading floor issue. “We hire good people: good culture and behaviours should come naturally.” “99% of our people behave right; bad apples let us down.” “Sorting this out is all about aligning compensation and incentives.” “It is only a problem on the trading floor.” 4Copyright © 2015 Accenture All rights reserved.
  4. 4. Regulations are driving change in the practical ‘cultural frameworks’ within financial services companies – new policies, responsibilities and controls Copyright © 2015 Accenture All rights reserved. 4 2016 - 172015 UK June: Complaints Handling May: MiFID II January: MiFID II June: MiFID II June: SMR May: Whistle- blowing June: Whistle- blowing June: Fair and Effective Markets September: MiFID/MiFIR March: SMR March: SMR, Certification July: MAR July: MiFID/ MiFIR Q2: FCA investment and corporate banking market study EU UK UK UK UK UK UK UK Q2/Q3: FCA Culture Change UK Q3: Consumer Data UK Q1: Dark Pools Product Governance Conflicts of Interest UK EU EU EU UK UK Whistleblowing Market Conduct Digital/Data Pipeline of Conduct Regulations and Guidance in Europe – 2015-17 Personal Accountability Complaints Handling Key Themes: Source: Accenture analysis based upon publicly available documents, November 2015. Glossary: FCA: Financial Conduct Authority MAR: Market Abuse Regulation MiFID: Markets in Financial Instruments Directive MiFIR: Markets in Financial Instruments Regulation SMR: Senior Managers’ Regime
  5. 5. What does good culture look like? 1. Responding to the ‘spirit of the law’ Copyright © 2015 Accenture All rights reserved. 5 Adapters to Regulation (‘Letter of the Law’) Transformational influence Shapers of Standards (‘Spirit of the Law’) Banks RegulatorsTrusted Industry Leader Short-selling Digital Channels Market Abuse Risk Reporting … Examples
  6. 6. Employee Business Unit Board and CEO Customer What does good culture look like? 2. Identifying which touchpoints best influence behaviours and culture Recruitment Reward and recognition Capital allocation Talent management Learning Promotion and succession Shareholder and Analyst interactions Board diversity Strategy Marketing Staff attitude Service value and ROI Copyright © 2015 Accenture All rights reserved. 7
  7. 7. Product Governance Committee Business Unit Exec. Committee Group Compliance or Risk What does good culture look like? 3. Empowering people to make better decisions and take action Copyright © 2015 Accenture All rights reserved. 7 Board Conduct Data ‘Universe’ 50-100 Indicators Influence Groups Start here! Useful Conduct and Culture Indicators Examples % actual v forecast profitability, by product Helpful Unhelpful % complaints for sales by robots v humans % products sold in bundles % employees rated as role models Products w/ no alt’s for vulnerable customers Culture Products Customers Markets Governance % trade orders cancelled Breaches by senior personnel With qualitative input, this data turns to insight – colour, root causes, exceptions, follow-up actions
  8. 8. Risk Culture and Conduct in Practice: What does ‘good culture’ look like? 8Copyright © 2015 Accenture All rights reserved. Disclaimer: This presentation is intended for general informational purposes only and does not take into account the reader’s specific circumstances, and may not reflect the most current developments. Accenture disclaims, to the fullest extent permitted by applicable law, any and all liability for the accuracy and completeness of the information in this presentation and for any acts or omissions made based on such information. Accenture does not provide legal, regulatory, audit, or tax advice. Readers are responsible for obtaining such advice from their own legal counsel or other licensed professionals. About Accenture Accenture is a leading global professional services company, providing a broad range of services and solutions in strategy, consulting, digital, technology and operations. Combining unmatched experience and specialized skills across more than 40 industries and all business functions—underpinned by the world’s largest delivery network—Accenture works at the intersection of business and technology to help clients improve their performance and create sustainable value for their stakeholders. With more than 358,000 people serving clients in more than 120 countries, Accenture drives innovation to improve the way the world works and lives. Its home page is www.accenture.com. Accenture, its logo, and High Performance Delivered are trademarks of Accenture.
  9. 9. Thank you. Visit our new Conduct and Culture Blog: www.accenture.com/ConductandCulture 9Copyright © 2014 Accenture All rights reserved.

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