Last week, Canada's Office of the Superintendent of Financial Institutions (OSFI) issued a regulatory notice setting forth its expectations for culture risk management in the financial sector.
"Culture influences behavioural norms, which send signals throughout an organization about what is, and is not, valued, important, and acceptable. Culture supports or undermines sound decision-making, prudent risk-taking, and effective risk management," OSFI writes therein. “This, in turn, can materially support or weaken a financial institution's safety, soundness, integrity and security.”
In the notice, OSFI provides guidance for how leaders can foster a desired culture in their organizations. Culture, OSFI explains, can be deliberately shaped and maintained through effective leadership, talent management, incentives, and accountability. The regulator encourages leaders to model the desired culture and apply a consistent approach to people management practices.
Firms should also endeavor to manage the risks associated with the organizational culture proactively. They can do so by developing measures to assess culture risk, revealing root causes of risk, leveraging monitoring processes to allow for oversight, and continuously reviewing the effectiveness of their culture risk practices to drive improvements. Culture risk management should also be integrated within the enterprise-wide risk management program, OSFI writes.
In an interview for Starling's 2022 Compendium, Peter Routledge, Canada's Superintendent of Financial Institutions, discussed how OSFI seeks to regulate and supervise the non-financial risks stemming from organizational culture.
"In the culture taxonomy that we have created, diversity of thought, leadership, and group dynamics are examples of areas where we can begin to assess effective culture practices," Routledge said. "Future work includes looking more closely at senior executive compensation structures and related measurement to support and reinforce a culture of integrity and effective risk management at all levels." ▸ Read More
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