The essays from financial leaders in the FCA’s new discussion paper DP20/1 ‘Transforming culture in financial services: driving purposeful cultures’ highlight many interesting employee engagement themes for those of us who work with firms to embed corporate purpose and culture. In particular:

  1. Psychological safety and the ability to ‘speak up’ and voice concerns remains a key feature of the FCA outlook – validating the proactive whistleblowing and anti-harassment programmes employers put in place;
  2. The key requirements for employee commitment are autonomy, competence and sharing – which rings true in everything from managing grievances, to restructuring teams, to drafting codes of conduct;
  3. Purpose and culture should be discovered rather than imposed – highlighting the value of employee engagement in workplace change rather than management edicts;
  4. Authenticity of purpose is key – and working towards that can be an intrinsic motivator rather than some reliance on the extrinsic (pay) alone;
  5. Tone from the top remains important but can also be off-putting to employees if they don’t understand how they can enact it in their day to day working lives – hence the value of a cultural change approach that is embedded at both a micro and macro level. This highlights, too, the value of something like the FCA SMCR code of conduct applying at every level of an organisation, as firms use that as a tool for cultural change.

What is the best way to achieve this?

The discussion paper is about more than just employee engagement. It is about stewardship, investment, and purpose for profit. But as boards and HR professionals alike will know: a change that doesn’t draw in the workforce will not be sustainable.

Our clients use a range of tools to achieve this purpose and culture is embedded: from consulting employee focus groups on policy change, to normalising cultural ‘interventions’ where employees can call out purpose drift, to designing board agendas that align to implementation of corporate culture. 

Undoubtedly, this paper will provoke further discussion about the best ways of doing this, and I look forward to being part of those debates.


Please note this blog post was written by a Clifford Chance LLP employee. Clifford Chance LLP is the parent company of Clifford Chance Applied Solutions (CCAS). The content within this post does not constitute legal advice.