Conduct & Culture Roundtable 2026: From Culture Statements to Cultural Evidence

Tea, coffee and pastries on arrival. An opportunity to meet peers across HR, compliance, risk and the executive function ahead of a working session that asks more of the room than the average roundtable.

Framing the day. Every firm has a culture statement. But how many firm’s can prove it is real? With Consumer Duty embedded, non-financial misconduct enforcement biting and the FCA increasingly looking past policies to behaviour, the gap between cultural narrative and cultural reality is now a board-level question. The morning is structured to close it.

Delivered by Macfarlanes

A 10-minute regulatory and supervisory read-out. Where the FCA actually is on culture in 2026, what has shifted in tone and substance over the last 12 months, and the legal and regulatory exposures wealth and advice firms are most likely to underestimate. Sets the bar for the rest of the morning.

• Where culture sits in current FCA supervisory priorities and what that means in practice for wealth and advice
• The non-financial misconduct rules and the post-Staley landscape – what is now in scope and what firms are still treating as out of scope at their peril
• Consumer Duty as a cultural test – how supervisory expectations have evolved beyond the original go-live framing
• Recent enforcement and Final Notices – the cultural patterns the FCA is naming, not just the conduct
• What good cultural evidence looks like to a regulator, an acquirer or a court

Consumer Duty in Practice: From Box-Ticking to Cultural Transformation

Three years in, Duty implementation is largely done. Customer outcomes are not yet consistently better. This panel keeps a tight focus on the customer-facing test: are firms producing genuinely good outcomes, can they evidence it, and where does the operational chain – product, distribution, post-sale care – still fail the customer? The wider organisational and strategic culture questions are picked up in the next session.

• Good outcomes in evidence – what wealth and advice firms can now demonstrably show is better for clients under Duty, and where the honest answer is ‘not yet’
• Cultural indicators of customer outcomes – the leading indicators firms are using beyond complaints data, and the lagging indicators that have stopped earning their place
• Vulnerable customers and the harder cases – where Duty has changed practice meaningfully and where good intent is still failing to translate into a different client experience
• Capability at the front line – where Duty actually lives or dies, and where firms are over-relying on policy to do work that adviser and front-line capability should be doing
• The chain that fails the customer – product, distribution and post-sale care as one chain, where the seams still show, and the failure modes when they don’t behave as one
• Drift, fatigue and the next 12 months – keeping Duty live as the project energy fades, and what ‘good’ will look like under continued FCA supervisory focus

Panellists:

• Gary Lynam, Managing Director, EMEA, Protecht
• Adrian Harvey, Chairman and Co-founder, Elephants don’t Forget
• Richard Bernstein, Compliance Director, JM Finn

Culture as Strategy: Embedding Ethical Decision-Making Across the Organisation

Where the previous panel looked outward at the customer, this panel looks inward at the firm. Culture-as-strategy means a board-owned, organisationally embedded set of behaviours that hold up under stress – growth, acquisition, leadership change, commercial pressure. The question is not whether the firm has the right values on the wall, but whether those values survive the next M&A deal, the next ambitious hire, the next quarter when commercial and cultural signals point in different directions.

• Board ownership of culture – what it actually means for the board to own culture, beyond the annual culture report, and what tells you whether ownership is real or nominal
• The ExCo signal – where day-to-day senior leadership signals (what gets rewarded, what gets tolerated, who gets promoted) reinforce or quietly undermine the stated culture
• Culture under organisational stress – how growth, M&A and consolidation, leadership turnover and rapid hiring damage culture, and the controls that protect it
• When commercial and cultural signals disagree – the moments when the strategy and the stated values genuinely pull against each other, how good leaders resolve it honestly, and how weak ones paper over it
• Ownership across the lines – culture sits awkwardly between HR, risk, compliance and the first line; in well-run firms, who actually owns it, and where does ownership most often get lost?
• Culture as a strategic asset – the firms treating culture as something that compounds over time, not just something that has to be reported on

Panellists:

• Joanna Shackleton, Head of HR / Partner, LGT Wealth Management
• Frank Brown, GRR Consulting
• Claire Foy, Executive Leadership and Team Coach; former Head of Capability, Coutts Bank

Cultural Measurement in 2026: What’s Working and What Isn’t

Every firm in this room measures culture. Few would claim the measurement is credible. This panel is the practical climax of the morning: what cultural evidence actually stands up to a board, an FCA review or an acquirer’s diligence, what no longer earns its place, and how to combine quantitative MI with qualitative insight without producing something an experienced practitioner can game in their sleep.

• What boards and the FCA now trust as cultural evidence – and what gets politely received but doesn’t move the dial
• The metrics that no longer earn their place – which long-standing indicators are firms quietly retiring, and what’s replacing them
• Quant and qual without gaming – the integration that actually works, and the dashboards that tell you nothing
• Industry frameworks – the ACT Framework, FICC standards and similar initiatives, what they’re delivering, and where they need to go further
• Culture MI in practice – what a credible board pack looks like in 2026, what cadence works, and the questions a non-executive should be pushing back on
• Surveys and listening – where they add real value, where they create false comfort, and what should sit alongside them
• Inclusion and conduct risk – the increasingly clear evidence that weak inclusion signals weak conduct, and what that means for measurement

Panellists:

• Frank Brown, GRR Consulting
• Bhavini ‘Bev’ Shah, Co-Chief Executive, City Hive

Cultural Measurement in 2026: What’s Working and What Isn’t

Every firm in this room measures culture. Few would claim the measurement is credible. This panel is the practical climax of the morning: what cultural evidence actually stands up to a board, an FCA review or an acquirer’s diligence, what no longer earns its place, and how to combine quantitative MI with qualitative insight without producing something an experienced practitioner can game in their sleep.

• What boards and the FCA now trust as cultural evidence – and what gets politely received but doesn’t move the dial
• The metrics that no longer earn their place – which long-standing indicators are firms quietly retiring, and what’s replacing them
• Quant and qual without gaming – the integration that actually works, and the dashboards that tell you nothing
• Industry frameworks – the ACT Framework, FICC standards and similar initiatives, what they’re delivering, and where they need to go further
• Culture MI in practice – what a credible board pack looks like in 2026, what cadence works, and the questions a non-executive should be pushing back on
• Surveys and listening – where they add real value, where they create false comfort, and what should sit alongside them
• Inclusion and conduct risk – the increasingly clear evidence that weak inclusion signals weak conduct, and what that means for measurement

Panellists:

• Frank Brown, GRR Consulting
• Bhavini ‘Bev’ Shah, Co-Chief Executive, City Hive

Phase one is live – and the cultural risk inside the streamlining

The administrative burden has lightened. The cultural question is whether accountability has lightened with it.

• The 12-week rule loosens hiring pressure – but candidates now sit under Senior Manager Conduct Rules from day one. Whether your firm treats them as a Senior Manager from day one, or quietly waits for approval to make it real
• The six-month SoR/MRM notification window – administrative relief, or quietly the moment when senior accountability stops being live in board conversations between submissions
• Digital certification and embedded HR processes – convenience that risks turning fitness and propriety into a process the firm runs rather than a judgement the firm makes
• Senior managers’ sharper notification obligations – what it actually feels like inside the firm when failure to escalate is itself a breach, and whether that conversation has happened with your SMF holders

10^th July – when scope changes, what holds the culture?

Most firms in this room won’t move scope. The threshold uplifts catch only the largest firms or those near the old limits. The cultural risk is mistaking the broader streamlining narrative for a signal that accountability expectations are easing. They aren’t.

• Falling out of the enhanced regime – which of the controls earned their place culturally, and which were always just compliance furniture? The honest distinction
• Streamlining duplicate certifications – the risk that the controls sitting alongside them quietly leave too
• SMF18s now able to hold any prescribed responsibility – flexibility that supports how the business actually runs, or the moment accountability subtly diffuses?

Phase two – preparing for the Financial Services Bill landing the day after this event

The Bill is expected in the King’s Speech on 13^th May. The cultural question for firms is what carries the weight when the statutory scaffolding is removed.

• Removal of the certification regime from FSMA – when annual recertification stops being a legal requirement, what should your firm voluntarily keep doing, and why?
• Fewer SMFs requiring pre-approval – fitness and propriety judgement shifts from the regulator’s gate to your internal governance. Is your governance ready to carry that weight credibly, or has it relied on the regulator doing the hard part?
• SoRs and conduct rules moving from statute to rulebook — what changes culturally when the rules can move faster than parliamentary scrutiny? How does the board stay close to a regime that can shift between meetings?
• Time-limited and conditional SMF approvals – the cultural challenge of normalising these so they’re a tool, not a stigma

The collision with NFM go-live on 1^st September – culture as the deciding factor

SMCR streamlining and NFM expansion arrive in the same 16 weeks. Where the rules contradict or leave room for judgement, culture will decide what your firm actually does.

• The ‘material risk’ threshold – having a clear, lived framework for when conduct crosses the regulatory line, and resisting the cultural instinct to either escalate everything or quietly bury difficult cases
• HR, Legal and Compliance functions converging on conduct decisions – historically three parallel conversations; culturally, can your firm hold one
• Line managers exercising judgement rather than escalating by default – the capability gap most firms still have, and whether the culture supports a manager who makes the call versus one who passes it up
• Senior managers’ self-reporting obligations – the cultural test of whether your firm is a place where a Senior Manager would actually self-report, or one where they wouldn’t

Roundtable host: Macfarlanes

1. Measuring and Managing Culture: MI, Storytelling and Indicators that Matter

The practical companion to the 10:40 panel. This roundtable goes deeper into the mechanics: what to measure, how to triangulate, how to present cultural evidence so a board engages with it rather than nodding it through.

• Indicators worth tracking – leading vs lagging, behavioural vs structural, and the half-dozen metrics most firms could usefully retire
• Triangulation in practice – using quantitative MI, qualitative insight and narrative case examples without producing a confused report
• The board pack question – frequency, format and the difference between MI a board looks at and MI a board acts on
• Anti-gaming – designing measurement that resists Goodhart’s Law and incentive engineering

Roundtable host: Frank Brown, GRR Consulting and Bhavini ‘Bev’ Shah, Co-Chief Executive, City Hive

1. Inclusive Conduct Cultures: Turning Values into Daily Behaviours

The evidence that inclusion and conduct risk are linked is now hard to dismiss. Firms with weak inclusion signals tend to have weak conduct signals, and the FCA has noticed. This roundtable moves past the values statement and into the operational reality – what changes day to day when a firm takes inclusive conduct seriously.

• Beyond the code of conduct – the gap between what’s written and what’s tolerated, and how firms close it
• Inclusion as a conduct indicator – using inclusion data as an early warning on conduct risk, not just a D&I report metric
• Performance, reward and risk – linking inclusive behaviour to performance management without it becoming gameable
• The micro-behaviours – meeting dynamics, who gets challenged, who gets credit, and why these are now conduct questions

Roundtable host: Claire Foy, Executive Leadership and Team Coach; former Head of Capability, Coutts Bank

A short close drawing the morning’s threads together. The cultural evidence question, the patterns that have emerged across panels and roundtables, and a clear ask of the room: what each firm should look at differently on Wednesday morning. PIMFA’s continuing programme of work on culture and conduct briefly signposted.

Hosted lunch. The conversations that didn’t fit into the formal sessions tend to happen here – we’d encourage attendees to use the time.