With the JFSC’s continued focus on culture and its impact on consumer outcomes, your firm should concentrate on identifying, examining and improving your internal culture.

However, the difficult question is how can firms accurately measure their culture?

1. With so many different factors influencing culture, including the business type, size and organisational structure, no two financial services firms will be culturally identical, and it can be difficult know where to start your investigations.
2. Determining if there are any aspects of your culture that could be viewed negatively by the JFSC should be the first stage of your investigation, as this can shape the supervision you receive.
3. If negative areas are identified, you should be actively seeking solutions to make improvements to those areas.

Do you need help determining or evidencing your culture?

COMSURE’S CULTURE ASSESSMENT FRAMEWORK IS AN EVIDENCED-BASED REVIEW THAT HIGHLIGHTS EXAMPLES OF GOOD AND POOR CULTURE.

Comsure ASSESS cultural drivers in three broad areas:

1. your leadership culture,
2. your operational conduct and
3. your cultural influencers.

Comsure LOOKS AT the important roles KNOWLEDGE, RESPONSIBILITY AND EVIDENCE play in ensuring your culture meets JFSC expectations. For example:-

1. How well do you know your culture?
   1. It is hard to demonstrate your culture to your customers and other stakeholders if you struggle to describe it succinctly.
   2. If employees struggle to describe your company’s culture in a couple of sentences, it is a sign that your culture does not have strong enough foundations to ensure it is consistent across your business.
   3. Finding out how well embedded your culture is across the organisation gives you a good baseline measure of how strong your culture is and the work that needs to be done.

2. Is everyone responsible?
   1. Promoting a positive internal culture is often perceived as the responsibility of senior management.
   2. Senior managers should promote a positive culture, AND it is every individual’s responsibility to maintain this throughout their work and across the company.
   3. The delivery of good customer outcomes should be a top priority for all employees and one of the main measures used to assess performance.

3. Evidence beyond policies
   1. Not only does the JFSC expect firms to abide by their set policies and procedures, but the regulator has also made it clear that firms must be able to evidence their culture.
   2. For success in this area, your management information must provide the right data to evidence that your culture is present and be monitored and actioned across the business.