Firms should have a culture that is both generic to the industry that we work in, and specific to the firm itself. But how is culture defined? There are several definitions, ranging from the quality in a person or society that arises from a concern for what is regarded as excellent, a particular form or stage of civilisation, the behaviours and beliefs characteristic of a particular group, and the development of the mind by education or training. Culture in the corporate world refers to the beliefs and behaviours that determine how a company’s employees and management interact and handle external business transactions. However, often the culture is implied, not specifically defined, and develops over time from the through the combined experiences of new staff with different experiences, each adding to the cultural tone.
The firm’s management set the tone of the firm’s culture. This in turn sets expectations for the behaviours of the staff and can be measured in demonstrating the effectiveness of the tone which is then relayed back to the management. This cycle in itself often contains a number of natural flaws. It may be the expectation of the firm’s management that in setting the tone of the culture the staff will follow it, but actually getting the staff to buy in to the culture is a much harder challenge. Then there is the biggest challenge of all, the challenge of change, both for staff already with the firm, and change for staff joining the firm with backgrounds from different cultures. And finally there’s change as the industry evolves, which affects everybody from the top down.
This was recently highlighted in a view voiced by the FCA’s Chief Executive, in that firms need to ensure that the culture is consistent with appropriate conduct outcomes. He also said that they (the FCA) understand that cultural change in itself is a challenge, particularly when there is an embedded culture that has developed over years, and therefore the firms culture itself can be resistant to change, and that the answer is not to tackle the culture, but to act on the sources of the culture.
This is where a Training and Competence scheme can help the firm embed culture, cultural change, and measure against desirable conduct outcomes from different sources. Training & Competence concerns itself with the development of individuals by education or training as identified through measuring against the standards that are laid out in the T&C Scheme, and the firm’s own cultural standards if separate, and the industry standards including Treating Customers Fairly. But how does Training and Competence assess and review cultural measurement and cultural change?
Measuring against clearly defined standards provides clear conduct outcomes, but what if the desired outcomes are not clearly defined?
Measuring against clearly defined standards provides clear conduct outcomes, but what if the desired outcomes are not clearly defined? Are the desired outcomes competency standards or cultural standards, or perhaps a combination of both? For example the firm might have a desired competency outcome of ‘engaging with customers’ and staff may do exactly that, and in doing so meet the competency standard, but if there is no cultural standard, or the cultural standard is not clearly defined as to ‘how the customer should be engaged’ should be demonstrated, the measurement of that standard may become unclear and may even become subjective if the measurement of ‘how’ is based only on the assessors’ opinion on another persons’ actions. Possibly the only real measurement is through customer satisfaction and then only if the customer words this in such a way that they clearly felt that they were engaged, or even not engaged, with the firm.
However well or otherwise a firm might communicate the culture to the staff there will always be an element of interpretation. People are individuals and if six members of staff were asked to deliver ‘engage with the customer’ it is highly likely that they would all interpret ‘engage’ in their own way, with six different outcomes as to how they ‘engaged.’ The fact that they have engaged will meet a competency standard as a simple measurement, how they engaged will be another measurement, and then the assessment will have to factor in whether the engagement met the firms’ cultural expectations.There is therefore a reliance on the firm not just expressing its cultural expectations, but also the way it expects the culture to be delivered, perhaps this may be achieved using a ‘what good looks like’ scenario, although there probably aren’t many firms that include that in their cultural directive.
If communicating culture expectations requires clear and measurable directives, and the associated challenges, a bigger challenge would be to communicate change to an existing culture, where there is not only the change to communicate but also the reason for the change and the change to the measurement of cultural outcomes.
Certainly the same process of communications is required, but where the firm has an existing culture it’s not only the culture that needs to, but also the staff need to change to adapt to the new culture, and people are natural resistant to change. If the people at the top, the firm’s management, themselves change, then change should cascade throughout the rest of the staff.
Like any process, change does not happen overnight so the stages of change need to be planned and the outcomes measure at each stage. For example the firm might decide that its existing method of providing ongoing servicing to its customer base needs changing for whatever reason, perhaps cost, or certainty that each customer is being properly serviced, so the firm might decide to reduce servicing visits from twice a year to once a year, or perhaps to service certain customers only by telephone or by skype, as opposed to physically meeting the customer.
Training and Competence can help deliver cultural change through reviewing and understanding the transition stages required from the old culture to the new culture, and then measuring the outcomes, challenging the sources of the outcomes where necessary and providing support throughout the change process to both the management and the staff.
