Strong culture is good business and conduct provides a lens into culture
Conduct and culture is top of mind of Boards and Senior Management. In recent years, there has been an increase in the number of high-profile instances of employees involved in collusive, manipulative and other forms of inappropriate business conduct in both retail and wholesale banking. Employee misconduct, coupled with organizational challenges to timely identify and address misconduct, has reinforced the need for risk management programs that focus on conduct, and protects, preserves and enhances the appropriate culture. Deloitte’s Conduct Risk services are focused on assisting organizations establishing a formal conduct and culture program. Our team provides advice to help organizations shift from a reactive to a proactive management of their business practices and employees’ behaviors.
- Conduct Risk Management Programs - We assist organizations design and build Conduct Risk Management programs to address regulatory requirements, specifically around sales and trading business practices in financial markets. Our work is focused on helping to enhance risk capabilities across the three lines of defense, to better identify, prevent and detect misconduct.
- Conduct and Culture Diagnostics - We help organizations gain visibility over vulnerabilities in their culture that may lead to misconduct events. We provide insights on senior management and employee attitudes towards risk and their overall alignment with culture values and beliefs.
- Market Conduct Risk Analytics Solutions – We support organizations as they enhance the oversight and reporting over key internal and external channels, such as how they leverage employee and customer issues escalation and disciplinary processes; how they link monitoring and surveillance programs aimed at detecting inappropriate transactions and communications to broader enterprise-wide compliance issues; and behavioral analytics that can help prioritize employees or groups of employees at risk of misconduct, who may need additional monitoring and investigation.
This paper provides an overview of the fundamental drivers of misconduct in the financial services industry, and offers insights that can help organizations improve conduct and restore trust.