Conduct and culture have been moving up on the regulatory agenda and should be a prominent feature for the Board and senior managers at firms across the industry.
Multiple instances of misconduct in retail and wholesale markets have left the industry vulnerable to a series of commercial and regulatory pressures. The industry will need to recalibrate the way that it sets the tone and sets the culture and the way it measures and rewards people for the way that they deliver against the strategic objectives.
When it comes to conduct and culture, the industry is dealing with a combination of commercial and regulatory pressures. The commercial pressures include the need to rebuild reputation and trust; to establish commercial benefits from taking a more customer-centric approach; to respond to growing competition from challenger banks; and to avoid or minimize the financial costs of misconduct (criminal actions, fines, remediation and civil actions).
To address this, an integrated approach is being taken by some organizations in implementing a regulatory compliance framework through a compliance officer. This involves developing and establishing a compliance methodology, policies, procedures and a training program. The benefits include:
Whilst the compliance function plays a second line of defence role within corporate governance, it also has a place in the first line of defence for its own activities with ownership, responsibility and accountability for directly assessing, controlling and mitigating risks.
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