Despite the current economic growth and positivity that governmental and regulatory advisers across the UK are forecasting, the financial industry is still experiencing ripples from the 2008 financial crisis. Financial services organisations are often seen in newspaper headlines and industry bulletin boards with tales of malpractice and demonstrations of poor values. It is no surprise then that the industry is still subject to customer suspicions.
In an attempt to combat these misgivings the regulator has introduced a number of key initiatives where ‘culture’ repeatedly plays a central role. The ‘Retail Distribution Review’ and ‘Treating Customers Fairly’ both revolve around putting the customer first and ensuring that they receive the best experience possible. Contributing to this customer centric mind-set is the adoption of the right behaviours, attitudes and ethics; in other words, ‘culture’. It came as no surprise that when, in May, Sir Richard Lambert concluded his yearlong review and consultation into banking standards, the recommendation was the establishment of a non-regulatory Banking Standards Review Council (BSRC). Already endorsed and supported by six of the UK’s largest banks and the largest building society this new independent body is to drive and monitor best practice within the banking sector in an effort to transform organisational norms and encourage the right culture; a culture where the customer upshot is paramount.
Interestingly, according to Sir Richard, an essential ingredient to ensuring successful adoption of culture change, is training; specifically, how do you teach standards and ethics and what does best practice look like?
“The BSRC should work with its different stakeholders to identify and promote good training practice across a wide range of banking activities. Where possible, it should build on existing foundations.” Recommendation 8 – The Banking Standards Review.
One of the key outcomes from this report is that while the BSRC will have oversight over training, they will not be directly assessing or accrediting training which organisations and suppliers provide, as contrary to what was originally suggested in the consultation document. This effectively means that organisations will not have to fundamentally redefine the training strategies and methods already in place, as the BSRC will be ‘building on existing foundations’ of training provision.
Unfortunately, when it comes to behavioural training, organisations cannot adopt a ‘one size fits all’ approach.
By focusing on developing best practices for behavioural and ethical training, the BSRC can support banks in raising behavioural standards and, subsequently, the way they are perceived by their customers. This approach has the potential to change training delivery across the entire industry, while retaining the cultural and bespoke training approaches that makes each organisation unique. However, this does raise a number of key questions; for instance: What is best practice? How can the BSRC justify that what works for one organisation would work equally effectively for another, particularly considering the range of banking institutes in terms of scale and target market? And how do you teach the ‘right’ behaviour effectively?
We can safely assume that traditional methods of delivering technical training will not be effective here. While linear eLearning modules are an excellent tool for delivering courses such as Anti-Bribery & Corruption or Data Protection, they don’t necessarily embed the ‘right’ behaviour within the individual. Likewise, although organisational values and business aims help to direct staff actions and behaviour, teaching these so they can be effectively embodied can be difficult. This report clearly conveys that ethical training should not be treated as a box ticking exercise and should be a fundamental part of the training curriculum.
Unfortunately, when it comes to behavioural training, organisations cannot adopt a ‘one size fits all’ approach. Instead, it can be argued that only through a blend of learning approaches can organisations successfully embed good behaviour across all role types. ‘Scenario based’ learning has already been proven to be more effective than the typical ‘multiple choice’ assessment approach; where the employee steps through a number of ‘decision points’ on a more comprehensive scenario, with the impact of their decision reflecting how the next part of the scenario plays out. Further reinforcement of the key messages can be made through regular manager to employee sessions; which go beyond that of their core competencies, and look at their approach to certain scenarios, using evidence from their ‘day job’ as support.
Managers sitting in on calls or peer reviews in the workplace are not a new method of evaluating an employee’s skills, but they are often the most effective method of observing employees in practice, although there is much debate as to how often these processes should take place during a busy workday. Most organisations already have existing processes that can be utilised or repurposed for the support of these initiatives. For example the logging of CPD and on the job training, management of Appraisals, or 360° Reviews are all processes that can easily be built upon and reinforced; using the learnings and experience from more traditional industries to reinforce the idea that training is not just something that happens in a room or on a computer.
Technology is key in this aspect; having a single system which can manage and deliver both compliance training and policy documents, as well as delivering ethical and behavioural training courses will be crucial
Organisations will have the support of the BSRC throughout this process. One of their key aims is to promote and champion good practice and they will hopefully provide a forum for learning and development executives industry wide, to tap into best practice policies, guidance on how other organisations are delivering this type of ethical training and share experiences for the benefit of the industry as a whole.
What is important, however, is that whatever approach organisations take, the BSRC will be taking a much greater interest in their training strategies and approaches and their effect on organisations. In order to demonstrate these strategies effectively, organisations will need their training course metrics, course adoption rates and employee results to be easily accessible. Whether this continues to be a single score from a piece of eLearning or a more subjective score by managers in a similar fashion to the existing performance reviews, this information needs to be collated in one place and available for quick and easy reporting. Technology is key in this aspect; having a single system which can manage and deliver both compliance training and policy documents, as well as delivering ethical and behavioural training courses will be crucial to the success of the BSRC and that of the organisations which opt in.
In due course, a single system with the ability to monitor all of the training and competency aspects of the business will put organisations in the best stead.
At this stage in the process there are still a number of unknowns, for instance the BSRC does not yet have a chairman, the legal structure has yet to be defined, and no other banking organisation apart from the initial seven have come on board; therefore it is difficult to know what the role of the BSRC will actually be in a years’ time. However we know changes are coming, and where organisations can generally start making steps to improve their processes. Banks will have to demonstrate their training strategy, and its effectiveness in improving behaviour, as well as that of staff competencies as is currently required of them by the regulator. The value of training strategies will be analysed in much greater detail than before, and organisational executives will want to see cohesive plans. Paper and database based processes to manage and report on training will no longer suffice; more comprehensive and ‘end to end’ systems will need to be established in those organisations that don’t already have them.
In due course, a single system with the ability to monitor all of the training and competency aspects of the business will put organisations in the best stead. Monitoring performance and competency should sit alongside learning management, and these business functions need to work in tandem to ensure that an effective and all round training programme is in place.
At Access Intelligence, we have significant experience in providing systems and processes that not only deliver world class training across a wide range of learning assets, but also provide the ability to marry this delivery up against training strategies and overall employee performance. Our learning management and training and competency systems are utilised by some of the largest banks in the UK, and we have the scope and scalability to support organisations who are only at the start of this journey, as well as those with existing comprehensive processes in place.
Our advice to customers across the spectrum? Of course we will all be watching these developments with a very close eye over the coming months, but organisations should be taking the time to review their current training processes now, and identify how behavioural training is delivered organisation wide. At the end of the day, these recommendations make sense to every business within its remit, and to those across financial services in general, regardless of the success of the BRSC. One thing is clear, organisations’ training strategies will continue to be ever increasingly scrutinised for their validity and effectiveness. Those who can demonstrate and deliver true value will flourish.