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Leading a culture of integrity Building trust ‘Doing the right thing ’ Case Study. Towry - Overview. Fee based financial advice All employees remunerated through salary All employees are shareholders We are agents of our clients

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Leading a culture of integrity

Building trust

‘Doing the right thing’

Case Study

towry overview
Towry - Overview
  • Fee based financial advice
  • All employees remunerated through salary
  • All employees are shareholders
  • We are agents of our clients
  • Our mission is to help client realise their financial dreams and avoid the financial nightmares
shaping our culture doing the right thing
Shaping our Culture‘Doing the right thing’
  • Why now?
    • Increased and complex regulation
    • Rapidly changing landscape - emerging profession
    • FCA focus on culture
    • Acquisition strategy
    • Client experience audit– behaviours & process
    • Status of Towry
    • Trust is at an all time low in FS

Employee engagement must be strong

That’s why now

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the importance of culture fca view
The importance of CultureFCA view...

Culture is like DNA.  It shapes judgements, ethics and behaviours displayed at those key moments, big or small, that matter to the performance and reputation of firms and the service that it provides to customers and clients.

Clive Adamson, Director of Supervision, FCA at the CFA Society - UK Professionalism Conference, London.

fca view on drivers of culture at a firm
FCA view on drivers of culture at a firm

These include:

  • Setting the tone from the top
  • Translating this into easily understood business practices
  • Supporting the right behaviours through performance management, employee development, and reinforcing through reward programmes
how will the fca assess culture
How will the FCA assess culture?

Draw conclusions about culture from what they observe about a firm, in other words...

  • Joining the dots rather than assessing culture directly via a range of different measures e.g.
    • How a firm responds to, and deals with regulatory issues;
    • What customers are actually experiencing when they buy a product or service from front-line staff
    • How a firm runs its product approval process and the considerations around these
    • The manner in which decisions are made or escalated
    • The behaviour of that firm on certain markets; and even the remuneration structures.
the challenge of behaviours and culture the overlooked element of internal control
The challenge of behaviours and cultureThe overlooked element of internal control

The elements that determine organisational resilience

Valid purpose, vision and values

How strong is this element of our internal control framework?

Effective operating and control model

Appropriate behaviours and performance culture

Necessary processes and systems

Delivering good governance and resilience depends on achieving and aligning three key elements

shaping our culture how do we assess our culture
Shaping our CultureHow do we assess our culture?
    • Towry already have
      • pulse surveys/employee engagement survey
      • MC3 management feedback
      • Appraisal discussions
      • Exit interviews
      • Whistle blowing policy
      • Code of conduct
      • Codes of ethics - professional bodies employees subscribe to
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shaping our culture how can we define our culture
Shaping our cultureHow can we define our culture?
  • Online survey – MoralDNA
  • Structure interviews – Principled Consulting
  • Governance review – PwC
  • Audit findings – PwC and Principled Consulting
  • Master Class for Exco & Board – Roger Steare, Corporate Philosopher
initial observations principled consulting pc structured interviews
Initial ObservationsPrincipled Consulting (PC)– Structured Interviews
  • We have heard much that reflects well on all Towry staff and have been impressed with the attitude and loyalty.
  • Internal communication is not always consistent. Silos exist and managers are inconsistent with the way news is shared and distributed.
  • Some feel they and the client have become marginalised under the pressure to meet FCA requirements. “Cumbersome” procedures was a recurring theme and this is being addressed.
  • Culture featured strongly with a wide range of views. Although things were seen as needing attention, overall the impression is that Towry has a decent culture which requires polishing and, especially with regard to Values, refreshing. There is a deep fund of goodwill which should not however be run down.
initial observations pwc governance review complaints handling product selection and bpm s
Initial ObservationsPwC Governance ReviewComplaints Handling, Product Selection and BPM’s
  • Towry is very engaged to ensure that its policies and procedures are aligned to its core values.
  • However, this is an implicit rather than an explicit alignment as Towry has not mapped its processes and procedures to its core values.
  • There is a risk that the behaviours required to bring the core values to life will be interpreted differently and inconsistently applied, thereby potentially undermining the core values that Towry is striving to achieve.
  • Additionally, from the interviews and other discussions PwC understands that in some cases Towry’s processes are seen as being over-engineered, cumbersome and time consuming to apply; an area that is understood to be currently under review.
shaping our culture
Shaping our Culture

What is emerging

We now have a benchmark from which to act

the challenge of behaviours and culture the key drivers of behaviour
The challenge of behaviours and culture The key drivers of behaviour

Intrinsic

motivators

Purpose – Why does the company exist?

Decisions and actions in the moments that matter that create the habits of practice

Results

How they act

Vision – The company it expects to be in the long term

Values – Who is the company?

Behaviours –What is right?

Reinforcers

Leadership actions

Business goals and outcomes

Structure

Operating models and procedures

Management Structure

Performance measures

Reward, training and talent

shaping our culture joining the dots
Shaping our CultureJoining the dots…..
  • Healthy Leadership
  • ‘Tone from the top’
  • ‘Stepping up’ – Senior Management Team
  • Coaching peak performance
  • Enhancing job descriptions
  • Towry code of behaviours
  • Polish up our values

Shaping our Culture

‘doing the right thing’

  • Regulatory expectations
  • Treating Customers Fairly
  • Definition of culture
  • Thematic Review
  • Decision making framework
  • Whistle blowing
  • Tone form the top
  • Measurement/internal audit
  • Decision Making Framework
  • Adopt
  • Evidence client & risk
  • Governance
  • Focussed communication
  • Management accountability
  • Pull v push
  • Corporate
  • Business
  • Role / office
  • Client Experience
  • Process & behaviours
  • Silos