Since the mid-1990s, when he began helping to build risk management frameworks in large international banks, Dr Roger Noon has been dissatisfied with the engagement approach that’s almost always employed. He felt that the change teams he worked in weren’t thinking deeply enough about how to create effective risk management cultures. Like most financial institutions at the time, they focused heavily on their technology platforms and control processes. But Noon realised that something was missing. It was like trying to clap with one hand, he says.

    “Having since been part of a number of culture change projects in organisations, I also wondered why they had not really worked as well as they could have,” Noon says, now a risk culture architect at financial institution HSBC. “And I realised it was because if I imagined myself as a punter, sitting in the midst of an organisation, no one was really engaging very deeply with me to understand what my thoughts were about ‘what good is’, how I experienced culture and how I contributed to it.”

    No one was really engaging very deeply with me to understand what my thoughts were about ‘what good is’, how I experienced culture and how I contributed to it.

    Noon took this simple insight to the Global Market Operations (GMO) business within the Global Banking and Markets (GB&M) division of HSBC in 2015. He created a method that attempted to bring together the business’s aspirational messages about the type of risk culture it wanted to create and the thoughts, insights and behaviours of the 3,500 people already working in GMO.

    The initiative scooped GMO an innovation award from the Institute of Risk Management in 2016 and caused a stir within other parts of GB&M. John Lloyd, chief control officer of HSBC’s Securities Services business (known as HSS) – and now acting chief operating officer – wondered whether Noon’s approach might work for him. His team wasn’t only thinking about how to improve risk culture; it was also refreshing the risk management framework. Could those two initiatives run in parallel and inform one another?

    Different perspectives

    “Roger and I have had a shared interest for some time around culture and how you are able to understand and evolve it within an organisation,” Lloyd says. He says that he already understood the value of creating a “tone at the top” because in a global organisation there has to be consistency in the messages and values that drive the organisation’s activities. And yet, he says, “Roger set a catalyst off with the work he’d done in GMO and the more I read about the topic the more I began to share a mutual belief with Roger that we needed to think of this from a different perspective.”

    He wanted to empower the people in HSS to drive the culture from the base, at the same time as pushing down global values from the top. But HSS is a different type of business to GMO. With 7,500 people it is over twice the size and it operates in 36 countries. It is also what is known as a “front-to-back” business, which means it serves customers and effectively operates as a complete business within HSBC. GMO, on the other hand, exists to support HSBC’s Global Markets trading operations and, therefore, arguably has a simpler structure and a more unified culture.

    “If I’m honest, we were nervous,” Lloyd says. “Some of my peers were sceptical because we hadn’t approached culture change in this manner before. Equally, we didn’t know what the take-up was going to be by the general population in HSS to contribute to this, because you’re asking people to give up a good chunk of their personal time, or to actually squeeze that in with the day job.”

    Noon came in as a part-time consultant in 2017 and Lloyd hired Alan McKinnon as the full-time global risk culture lead on the project. McKinnon was to work closely with Gary Dutch, global head of framework, governance and reporting, and Marcus Jones, global head of risk initiatives within the control office, who were revisiting HSS’s risk framework. If this was the team at the top, who would the wider team be? And how would they identify the right people and get them engaged?

    If I’m honest, we were nervous. Some of my peers were sceptical because we hadn’t approached culture change in this manner before.


    Lloyd and his close circle carefully profiled people across HSS and invited some of the most suitable ones to get involved as champions in the different functions and regions of the business. They established a network of risk culture working groups and, apart from those in London and Edinburgh, most of this network was built up remotely. “One of the things that was important to us in the design of the project was that, in each working group, there would be a lead but we didn’t want those leads to be from my control office,” Lloyd says. “Ownership is really important because we often find from a control perspective that if people feel like we are doing something to them, it doesn’t always get the traction and buy-in. Culture is about risk owners – people within the business – owning their agenda, driving it and not waiting for the people in risk and control to come and tell them what to do.”

    There still seems to be a sense of surprise among the leadership group that people engaged with the project so enthusiastically. Since the culture risk strategy was aimed at getting people to get involved in strengthening culture in ways that were relevant to them, the range of ideas that came back from places as diverse as Sri Lanka and India to Ireland and Edinburgh was encouraging. Some locations launched risk culture weeks; others focused on detailed analyses on how specific processes could be improved, and certain countries initiated risk culture award frameworks. In Ireland, for instance, there is a quarterly award of €250 if an employee is selected as displaying the most exemplary risk culture behaviours.

    “We initially used the working groups to define their risk cultures and evolved that gradually into how you measure that and how you improve it,” Lloyd says.

    Building a risk culture

    About 120 people were involved in 11 working groups across locations that represented about 80 per cent of the population in HSS, and each group was designed to include a broad range of people from diverse backgrounds, McKinnon recalls. He likens the process to Gareth Malone’s TV programme The choir, where a group of strangers are brought together and expected to sing in one voice by the end of the series.

    “That was the intention behind what we were doing in trying to get the whole organisation to talk with one voice about something they’d not really spoken about before, which was the culture they wanted to have,” he says.

    The first eight weeks were “immersive” with video-conferencing calls and workshops running back to back. McKinnon and his team synthesised the emerging 500 or so elements of the fledgling risk culture framework into a more consistent and manageable model using language that reflected how people had described their aspirations for the future risk culture of HSS. They fed that back to the groups.

    “We asked them to broadly make sure that all the words and phrases they’d given us were visible either directly by being embedded in the framework, or that they could see the essence of the things they wanted to have in the framework represented when it got played back to them,” he says.

    Once the groups were happy with the framework, McKinnon presented it to the HSS executive committee. By then, the risk culture framework had been organised into five themes. Five members of the executive committee took a theme each and examined it line by line to understand, challenge and, eventually, validate it. McKinnon then used the approved framework as the basis for a 24-question survey which he sent out to all 7,500 staff in HSS. About 30 per cent of recipients responded. This connection between the “voice” of the employees and a survey tool was key to the whole engagement approach.

    Assessing progress

    The survey aimed to measure – McKinnon prefers the word assess – how far the organisation was from its aspirational risk culture goals. “Assess is probably a better word to use because you can ask a bunch of questions that will give you an approximation of whether you are broadly looking rosy or not, and you might get a sense of where you can zoom in to areas of relative strength or weakness – but you should be wary of assuming deep precision in a sentiment-based survey that asks people about their culture,” he says. “It is not a scientific method.”

    A strong picture of staff perception on the strength of the risk culture in the organisation emerged from the survey. As well as providing a global, business-wide view, there was enough data to dig into detail at a more local, sub-culture level. The temptation would have been to pick out a few global weaknesses and ask everybody to focus on those – but McKinnon resisted that approach. He doubts it would have worked.

    “Pulling lever A on a culture change activity does not always get the same outcome at the other side of the system,” he says. That means that what might work in London, for instance, will not be useful in Sri Lanka. Instead, people in different locations worked to improve their own risk culture, and some of those initiatives were then taken up by other teams. Ireland’s recognition programme was reported on in HSS’s risk culture newsletter, shared in workshops and was taken up in a modified format in Luxembourg and then again in Singapore. The business maintains a sheet on SharePoint summarising all of the risk culture initiatives.

    Top to bottom

    In July 2017, at the same time as the survey insights were being digested, the executive committee engaged in an off-site exercise in which they needed to select the top three things they felt were cultural priorities in the business. They were split into four groups to avoid them attempting to reach an easy consensus. After they had chosen their priorities, they were encouraged to tell stories about why they believed those things were important. This exercise helped them create a collective view of risk culture from the top of the business, which they could then begin to marry together with the diverse range of views coming from the people working in the different regions.

    Noon says it would have been easy to take those top-level views and push them down into the newly formed risk culture groups. Instead, they synthesised the bottom-up and topdown feedback since, not surprisingly, differences in priorities came about because of the different roles and perspectives of the participants. Leaders tended to rank things like acting as a role model as important to developing risk culture. More junior staff asked for more effective basic awareness training on risks and processes. Others wanted to know how knowledge of risk could be shared across the different parts of HSS better. Properly understanding and then strengthening culture meant treating these different perspectives with equal importance.

    Now people turn up and they talk about their business and risk and controls and how they have been monitoring them for themselves

    While the results of the second all-staff survey have not yet been published in detail, initial indications are that there has been a measurable improvement across all five themes. In addition, the response rate is now at 50 per cent, which McKinnon sees as encouraging given one of the biggest risks to the project is that people tire of the initiative and stop engaging. The team is striving to get people in the organisation involved in change initiatives that suit them. They have developed a risk scenarios board game, for example; interactive, risk-culture training; and a suite of other activities that aim to appeal to their diverse staff base. The lessons learnt are filtered through to wider training and induction programmes. The activity that the programme has generated, the conversations it sparks and the way the business listens and acts on those is creating a more visible, stronger risk culture in HSS.

    Risk framework

    Dutch arrived at HSS about two years ago – not long after HSS’s operational risk framework had been rewritten. His responsibility was to ensure it was fully embedded into the business. The framework comprised 14 components, of which culture was one. The new risk culture project presented a good opportunity to ensure that the people side of operational risk management was treated with the same seriousness as the process and technology side.

    “We have found it really powerful to work alongside the culture programme and think about what culture means in practice as you start to embed a risk framework into the business,” he says. While culture can be a hard concept to get to grips with, the specific risk culture initiatives at HSS have helped Dutch focus on some of the issues that those projects aim to overcome or improve.

    For example, if there is a risk escalation process that needs to be addressed, Dutch considers the process side and its timeliness but also asks if people are riskaware, comfortable to speak up and adequately trained; whether, in short, there may also be specific cultural issues that need addressing. “That’s an example of where the risk framework and culture come together in a more explicit way than would probably have happened otherwise,” he says.

    Over the last year, Dutch and Noon have been working to raise the level of awareness among staff, emphasising that they are the owners of the risk and controls in their part of the business and creating a debate as to what that means in terms of day-today behaviours and decision-making.

    “When I first joined, I’d turn up with John Lloyd at a risk and control committee meeting and we would be telling the risk owners about their own risk,” he says. “Now people turn up and they talk about their business and risk and controls and how they have been monitoring them for themselves. It is a big mindset shift. It is about creating a risk culture and the ownership, awareness and leadership that it brings to risk management.”

    Keeping momentum

    McKinnon and Noon have moved onto other projects, and Vilma Midveryte, senior manager, risk strategy and initiatives in the control office, has stepped in to take the risk culture initiative to the next stage. Her first move was to boost the number of working groups from 11 to 40 with over 80 individuals who are either sponsors or champions for the programme. When existing people in the network start getting bogged down in work – all of the activity on the programme is voluntary – Midveryte may help find a replacement to keep the energy for the activities high.

    A volunteer’s time commitment to the programme can add up. To run an awareness week in a centre like Kolkata, for example, which has about 800 staff, could take weeks of planning and preparation, with some people needing to commit to it full-time. Similarly, the global rollout of 300 copies of the risk board game requires slick organisation and planning. Here, Midveryte has been experimenting with different approaches to make it as easy as possible for individuals to participate. One method has been to ask everyone who plays the risk game to share the results but then find one other team of people who will do the same, thereby spreading this activity across a wide group of employees. She also makes sure that volunteers get regular recognition from the central team for their work.

    Midveryte is thinking about how the project can be renewed and refreshed over the next few years. She wants those coming into the business to understand how important HSS’s risk culture is and invite them to get involved from day one. “There is also a particular risk that, when things start to improve and people see what they have achieved, that they will be tempted to drop off,” she says. “That is why we will need to keep reinventing ourselves and understanding better how we can keep that focus and interest going.”

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