Supervisory framework for assessing conduct and culture in the financial sector

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1 Supervisory framework for assessing conduct and culture in the financial sector Femke de Vries De Nederlandsche Bank June 17th, 2014

2 The Asch Experiment 2

3 Pre-crisis supervision 3

4 Post-crisis supervision 4

5 Why supervision on culture & behaviour? One of the causes of the crisis: not so much inadequate governance structures, but board and management behaviour within these structures People determine a company s performance Risks relating to behaviour may already be apparent, while financially everything seems okay: Behaviour has predictive value with respect to future financial performance Early intervention may prevent future problems More rules alone will not prevent the next crisis 5

6 Methodology 6

7 Conduct and culture is one of the pieces of the puzzle Financial analysis (financial experts) Conduct and culture (psychologists) Assessment of business models (strategic experts) IT Risk (IT auditors) Integrity risk (experts) 7

8 Culture Leiderschap: voorbeeldgedrag en bespreekbaarheid Besluitvorming: evenwichtig en consistent Communicatie: transparant 8

9 Supervision on culture and behaviour Het toezicht van is gericht op het identificeren en voorkomen van risico s Identifies die risks kunnen that voortvloeien may emanate uit from cultuur behavior en gedrag. and culture: both risk based and at random Risk based in case of: Het toezicht van is gericht op het beïnvloeden van instellingen om deze Incidents (financial or non financial) risico s Lot te of verkleinen changes the of board elimineren. or sr management in short period of time Financial problems High risk appetite Non compliant behaviour Naast traditioneel toezicht (solvabiliteit en liquiditeit) en niet in plaats van. Assesses these risks to cause institutions to eliminate these risks Focus on the question whether leadership, group dynamics and decision making contributes to the (economical) performance of a firm We will intervene in case of riskfull behavior or lack of follow up 9

10 Methodology Decision Making + Board Effectiveness Desk research Interviews Survey & Selfassessment Observations (meetings and log) First intervention Discussion of findings Reports Start of second intervention= tracking follow up 10

11 What is your opinion? Culture cannot be translated into audit standards Assessment of culture and behaviour should be part of any SAI risk analysis SAIs can play an important role in stimulating neccessary culture changes in public sector organisations 11

12 Results 12

13 Case-Findings 13

14 Case-Supervisory approach Report (on paper) Send to management and supervisory board => supervisory board and shareholder become involved, leading to several actions Bank itself replaces CEO and CFO and look for new CRO. is involved in short list and selection Intensive follow up with respect to leadership, group dynamics and decisionmaking New board is receiving coaching on behavioural change. 14

15 Key areas Culture change requires permanent attention of directors and auditors 15

16 General impact of supervision on culture & behaviour Inter vention cause effect Actual changes we see: governance and staffing: changing board composition changes in decision making processes: more structured decision-making processes, better preparation of decisions, more involvement of key control functions, evaluation of complex decision making, organizing constructive challenge and debate more facilitative leadership styles better information-sharing between the management and supervisory board 16

17 Final comments Every organization and every group may be affected by leadership problems or adverse group dynamics has found risky situations pertaining to culture & behavior and has caused the institutions to eliminate these risks We also found good examples However, there is still a lot more awareness needed and improvements to be made, which will take a lot of effort and time (change takes time!) Permanent Board commitment and attention for culture & behavior within financial institutions remains required to prevent adverse effects from behavior and insufficiently considered decisions 17

18 What is your experience? Our SAI is committed to an ethical culture and behaviour within our own organisation Our SAI has invested in facilitative leadership Our SAI systematically organises internal and external challenge, dialogue and debate Our SAIs decision making process is frequently evaluated 18

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