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I work with many different clients who find many elements of compliance and specifically the fair treatment of their customers is directly linked to their culture. Culture is such a huge issue for our industry and it’s a struggle for many firms.
The Financial Conduct Authority (FCA) 2019/20 business plan stresses the importance of culture and that it is not just about rules – we each have a personal responsibility. Lloyd’s of London has also recently changed its code of conduct following reports of a drinking culture.
In the FCA 2019/20 Business Plan, CEO Andrew Bailey stated that "For me, one of the key elements of a good culture is looking at what behaviours are accepted or even rewarded. Alongside this, I am always concerned where it feels like a company seems to accept inappropriate behaviour from a leader – often a charismatic person who seems the company is led by someone who is unconcerned about the views of others."
So, let’s consider how behaviour impacts on culture.
I am going to assume you are a good person - when you are home and spending time with your family and friends, you treat others with politeness and respect. If you have children, you spend time patiently teaching them the ways of the world. This doesn’t mean you are a doormat – you can still be assertive as well as a fair and ethical person.
So, what happens, when you step into the workplace? Do you become a different person? Do you work in an office where you are expected to get what is needed done at all cost? Do you suggest heads will roll? Do you talk over the women in your office? If this kind of behaviour is tolerated or even expected then you need to really think about whether you want to stay there. It can be very stressful – worst of all you can turn into someone who thinks this is acceptable behaviour.
I once worked for a company where in my annual review I was given greatest praise for a situation where I had lost my temper and become aggressive to get my way – it achieved results. I had not been proud of that reaction which was due to the fact I was being subjected to this kind of pressure from senior management. I realised I did not want to work in such a culture nor become someone who behaved that way. I resigned a few days later.
So, the key lesson is to be honest about who you are and how you behave.
Is your company one where all the power seems to be with one person and others accept normally clearly unacceptable behaviour from that person. They are able to do what they want without challenge. Do you see someone like that in your business?
An example of this is the forced hugging by Ted Baker boss Ray Kelvin –it is alleged he greeted people with a hug and also kissed their necks and ears. The company said hugs were part of the culture but were not insisted on, but staff said "It is part of a culture that leaves harassment unchallenged,"
It is also suggested that he asked young female members of staff to sit on his knee, cuddle him, or let him massage their ear and would regularly use sexual innuendo.
Is it possible you have seen and accepted (or maybe undertaken) behaviour you know is wrong but is expected in your workplace? Is there someone who behaves inappropriately and seems invincible?
If so, you have two choices. You can leave or raise your head above the parapet and make a difference. If you are not comfortable with raising the matter with your manager you can always use the whistleblowing process.
I was a victim of inappropriate behaviour some years ago and did nothing – a decision I bitterly regret. My own view is that we should challenge this. In words (usually) attributed to Edmund Burke “The only thing necessary for the triumph of evil is for good men to do nothing.”
Author: Sally Pearce (Conduct Matters Ltd)