While Conduct Risk and Culture are separate concepts, they are inextricably linked and regulators now see culture as a key root cause of major conduct failings in the financial services industry.

Following the tracker mortgage scandal and the Central Bank’s report into behaviour and culture in Irish banks, Conduct Risk and Culture have both been crucial aspects of the regulatory agenda.

In recent years, the CBI have become (and continue to become) more focused in the supervision of Conduct and Culture across all sectors, including wholesale markets.

This is most recently demonstrated by the proposed introduction of the Individual Accountability Framework (IAF), which aims to reduce Conduct Risk and improve Culture in the financial services sector, as well as the upcoming review of the Consumer Protection Code (CPC) and other significant initiatives at the EU level.

As regulatory scrutiny intensifies in this area and the reputation of firms is increasingly at stake, it is important to stay ahead of the Conduct Risk & Culture agenda by implementing preventative and detective controls.

Our Conduct Risk & Culture services comprehensively cover multiple areas of your organisation so that you can identify, monitor and mitigate risks effectively across several lines of defence.

Our Services

Complaints and Remediation
  • Complaint Management
  • Resource augmentation / Surge support
  • Error redress and remediation
  • Customer appeals processes
  • Complaint operating model review
  • Root cause analysis
  • FSPO dispute resolution and formal investigation support

Complaints and Remediation services

Consumer Protection & Governance
  • Vulnerable Customer programme
  • Conduct Risk Framework design, development, training and implementation
  • CPRA assessment authorisation support
  • Assisting firms prepare for a conduct risk inspection, including interview preparation (from PCF/CFs to front line staff)
  • Preparing for Conduct Risk Assessments
  • Compliance universes obligations register
  • RMPs remediation support
  • Behavioural Change – customer communication analysis
Culture
  • Organisational culture and behaviours assessment
  • Behaviours and culture framework design
  • Risk culture awareness (including in-depth interviews and board reviews)
  • Identification of culture and behaviour drivers
  • Conduct culture reviews as part of the internal audit plan
  • Tailored training
IAF/SEAR

Our market leading team of experts can ensure your organisation is set up for success throughout the various stages of compliance:

  • Assess your firm’s readiness to achieve IAF compliance.
  • Scope impacted entities and corresponding PCF and CF role holders.
  • Deliver training at individual, level-specific and firm-wide levels.
  • Develop and implement processes and documentation across all four areas of IAF.
  • Assess processes in place to verify your compliance with industry standards.

Why Grant Thornton?

Grant Thornton has a wealth of experience in Conduct Risk and Culture across all financial services sectors. Our multi-disciplinary team of experts includes experienced industry practitioners and former regulators who can provide you with practical advice, support and meaningful, informed insights.

Office close to you

13-18 City Quay

Dublin 2

D02 ED70

Ireland