How can SM&CR drive real culture change?

The FCA has made it clear that the extension of the Senior Manager and Certification Regime should be about culture change (creating a ‘Culture of Accountability‘) rather than ‘tickbox’ compliance. However, the level of detail and guidance around SM&CR and culture change, what this really looks like, and how to achieve it is notably absent. Of course, this is because culture change is easy to say but far more difficult to achieve in reality. Few firms will know instinctively how to achieve culture change or may not even believe they need it.

Culture usually sits with HR; SM&CR usually sits with Compliance.

In larger firms, it may not be clear whether SM&CR should sit with Compliance or HR or straddle the two with the risk that it is owned by neither. In smaller firms, due to limited resources, it may all sit on the shoulders of one or the other. This white paper considers these challenges, offering practical suggestions on how to address them and benefit in the process. We would argue that the two processes can integrate well with each other. To find out more, read our blog: how to use SM&CR as a catalyst for engagement.

Let’s consider the necessity for culture change

What do we actually mean by culture change and what culture are we moving from and to. Clearly, the main focus of the FCA mandated culture change around SM&CR is about increased responsibility and ownership around risk. One of the challenges with SM&CR is that some perceive the risk to Insurance and other Financial Services as less, comparable to the banks. Therefore, there is less buy-in to the requirements for change. This is likely to increase the odds of people simply going through the motions in terms of Conduct and Certification. Should this view be challenged? Certainly, firms subject to the extended regime pose less of a risk to the economy should they get things wrong compared to Banks. But surely consciences should still be stirred if the risk of misplaced investment or insurance could cause more damage and pain to individuals than entities?

The FCA has provided increased incentive for change by shifting potential penalties for SM&CR breaches from the firm to the individual, but only a handful of Senior Leaders are acting as true trailblazers for behaviour change currently. Perhaps it is down to HR & Compliance to help Senior Managers realise the potential personal risks that could arise from not taking the regime seriously.

Case Study: GRP adopts SM&CR Software

Discover Actus Comply SM&CR Software

Download this White Paper

Please fill out the form below to receive a link to your whitepaper on SM&CR & culture change.

    Not quite ready for a Demo?

    Please complete the details to receive a 3 minute system tour direct to your inbox!

      Request a quote today

      If you are looking for performance management software for 1000+ employees get in touch for a quote today.

        The 360 Tool for Independent Consultants

        Talk to one of our partnership specialists today.

          Not quite ready for a demo?

          Fill in your details below and then please check your email for a link to the 3 minute overview of Actus Software

            Get in touch with us today!

            If you have any questions, enquiries or just want to say how much you like us (or what we can do better), please drop us a line.