Emily Shepperd, FCA Chief Operating Officer, recently delivered a speech titled “Culture is Contagious.” But why does the FCA care about culture?
Culture drives conduct and decision-making, which directly impact outcomes for consumers, markets, and our economy. For this reason, culture will continue to be a regulatory concern.
Repeatedly, when the FCA investigates failures of consumer protection or market conduct, they find the same root cause: failings in culture and governance.
That is no coincidence. Culture drives conduct, shaping decisions and actions at every level. And those decisions, whether they’re made in the showroom or in the boardroom, directly impact outcomes for consumers.
The speech referenced a recent fine for Volkswagen Financial Services October in 2024: £5.4m fine and £21m redress payments for not treating its customers that were in arrears fairly.
The lesson for the financial services sector is clear: cultures that encourage open dialogue, constructive challenge and learning from failure, fuel innovation, agility and longer-term success.
One of the clearest warning signs of a failing culture is non-financial misconduct, which includes behaviours such as bullying, harassment and discrimination.
Turning a blind eye to toxic behaviours not only drives away good staff, but raises serious questions about a firm’s wider decision-making and risk management. Environments where people don’t feel psychologically safe to speak up can become breeding grounds for even bigger problems – hidden mistakes, ignored risks, and ultimately, harm to consumers and our markets.
And that is why healthy firm cultures are, and will continue to be, not just a moral issue, but a regulatory concern too.
Toxic cultures, left unchecked, can cause lasting damage – for employees, consumers, firms, markets and the wider economy. Outside of Shepperd's references, there have been some recent extreme examples in the motor industry of motor dealers sentenced for clocking cars, a valet dismissed for relieving himself on the customer’s car and caught on the dashcam, fraud by channelling transactions through a personal bank account, and lying to a customer that their car hadn’t been sold and keeping the money.
The good news? A healthy culture can stop harm in its tracks and spread benefits far and wide.
Be confident with ITC
ITC agrees that a healthy culture is a very good thing, and this is why considering culture is an important area in ITC’s audits of network members. We work with our member firms to advise them so that they can do business in a compliant manner, and ensure that customers are always getting good outcomes.