Do you provide the right conditions for your culture to thrive?
By the time you are reading this, Consumer Duty for new and existing products and services that are open to sale will be nearly upon us or already in force. By now, the FCA expects all firms to have made the necessary changes to policies, processes, governance and culture to ensure that you are acting to deliver good outcomes for your retail customers.
To help you start thinking about the culture in your organisation as part of Consumer Duty, I like to think about something that I learned in school: the, ‘what, when, where, why and how’. I remember being shown the rugby posts (resembling the letter H), with five bare bottoms perched on it as a way to remember these words (maybe my teacher had a funny sense of humour). At school, this English grammar technique was designed to help children create questions when writing stories. But for me now, I believe this little primary school technique should be used to help define your culture in a way that will help satisfy the regulator when it comes to Consumer Duty.
Now I’m not saying that making changes to your policies, processes and governance hasn’t been painful, but this is where your Consumer Duty journey began. From October 2022, you will have decided by way of your implementation plan what actions needed to be done. You understood how you were going to fulfil those actions, when those actions were required, and where within your businesses those actions were taking place. But hand on heart did you truly understand why you were having to take on this gargantuan piece of work?
Truly understanding the why is always the missing ‘bottom’ on everyone’s rugby posts.
Have you ever asked a member of staff, ‘Why do you read that section of your script?’, ‘Why do you complete your after-sale notes?’, or ‘Why do you have to disclose our administration fee?’. I’m sure the majority will reply, ‘because I’m told to’ or ‘because that’s what I have to do as part of my job because we are regulated’. You couldn’t say to those members of staff that they were wrong, but we all know it’s far more than that (and not just because the regulator told us to!).
Consider your Team Leaders and Managers. If you were to ask them, ‘What do you do in your role?’, would their responses be, ‘I ensure my staff sell the required insurance products correctly’, ‘I ensure my staff follow all operational processes’, or ‘I manage the day-to-day activity of my team’. Take it one step further and ask your Team Leaders and Managers, ‘How do you perform your role?’, and I’m sure they all would answer with very professional responses.
Now consider what responses would you receive when asked, ‘Why do you do your role?’
Apply this to your Senior Managers and ask all the what, when, how and where questions, and once again they will all come back with extremely complex and thorough responses, each response with as much clout as the other, but what will the reactions be to the ‘why’?
How many when asked the ‘why’, respond with, ‘everything I do is to ensure our customers receive the best service’? I imagine only the few.
So how is this going to change?
I believe many firms are already working extremely hard to ensure their customers receive excellent service, but what I feel is lacking is the full understanding of, ‘why am I doing this?’
This is where education comes in. Culture (good and bad) is easily formed because from its centre it can grow. Education creates that centre of all organisations and from that your culture can easily grow. Education comes in many forms: training and competence, skills-based training, coaching, mentoring and on a regular basis by using active listening skills and understanding the meaning of what is being said. If all of these are all pulled together, it provides everyone with the knowledge, skills and empowerment to ensure your culture thrives.
Starting from top to bottom.
As Senior Managers sitting at the top of the tree looking down, you have such integral roles to play in the encouragement of education across your organisations and this includes your own. I’m certainly not saying you amazing people who are running these organisations are not educated. In fact, working in this complexly regulated sector, I believe you are probably some of the most educated. However, education isn’t just about qualifications and business degrees. Education is about having the knowledge, ability and skills to understand and learn from every aspect of your business.
When SM&CR regulation came into force, it wasn’t to just reinvent the wheel, what it created was the opportunity for Senior Managers to really focus on their actual responsibilities within their firms. This in turn created fantastic educational opportunities for Senior Managers, (and I’m not talking about learning about SM&CR), as it allowed them to delve headfirst into their areas of responsibility and work within them to make them the best they can be for their customers.
SM&CR also provided Senior Managers with a second educational opportunity. It has allowed them to work more closely with their teams to ensure everyone within those teams have the knowledge and skills needed to service their clients to the best of their ability. By working with your teams, you can inspire the next generation of leaders. Don’t forget leaders do not have to be managers, they can be the staff who are going to grow your culture and lead the way to ensuring good outcomes are achieved for your customers.
As we move down the organisational chart, let’s look at Team Leaders and Managers sitting at the coalface. How are they seeking educational opportunities for their teams and themselves to ignite and embed the culture your business is striving for? There are so many educational opportunities that can be identified by your Team Leaders and Managers directly from working with their team instead of over them. As Team Leaders and Managers, they need to inspire their teams, in the same way as Senior Managers need to inspire them.
Would your Team Leaders and Managers be open and encourage their staff to give constructive criticism of internal processes either following customer feedback or even their own thoughts and feelings? Even if the feedback was heard, would your Team Leaders and Managers follow through? Do your Team Leaders and Managers understand the customer complaints that are received into their teams? If so, do they dig right down into the cause and work with their staff to fully understand how the complaints arose and work together to put them right?
Remember, customer complaints (although one of the toughest parts of anyone’s role) gives you the opportunity to make the most positive impact on a customer’s interaction with you. During one to one, coaching and monitoring sessions, do your Team Leaders and Managers really understand their staff members’ knowledge and skills gaps, or do they just ask, ‘are there any courses you want to go on?’. On the flipside during a one to one, if a member of staff failed their call monitoring would the Training Department be called in without fully understanding why the staff member’s performance wasn’t at the acceptable level? These are all opportunities that your Team Leaders and Managers need to take, and by seizing them with both hands, they will instil the culture you are wanting to grow.
Finally, let’s think about your business as if it was part of a school biology lesson. I recently read within a scientific journal: cell cultures fail for one of two reasons, the culture conditions or the actual cells themselves, and although I’m certainly not comparing your staff to organisms in a petri dish, your culture can only fail if you haven’t got your conditions right or your staff haven’t been educated enough to believe in it and grow. Think about which staff are the most important cell of all the cells within the culture growth. These are cells who need the very best conditions to grow. Make sure that you give them the best opportunity to do so. Help them to understand the why.
Compliance Consultant, UKGI
This article was published in the July edition of TC News, a quarterly magazine for people development and people regulation personnel within financial services.