At a banking industry conference in June, Comptroller of the Currency Thomas Curry pointedly said that boards are responsible for their banks' cultures. "Healthy culture starts at the top," he said. "It's the job of the board, in combination with management, to articulate what the institution stands for."
Should bank directors be alarmed at this ratcheting up of their already considerable responsibilities? We don't think so. In fact, they should be relieved. Boards that put culture first are more likely to get compliance, risk, soundness, and other potential sources of problems right than boards that go at addressing these issues the other way around. As we wrote recently, "culture is the most comprehensive way to pull all of the disparate parts of a financial firm together and get them moving in the same direction for the long term."
That said, it's understandable that board members may feel wary about taking on culture. As Curry observed, culture is "more amorphous and difficult to quantify" than, say, liquidity. Moreover, boards are far removed from the day-to-day operations that weave the fabric of the culture. But that's all the more reason for boards to provide their institutions with an overarching common purpose — such as putting the customer's interests first — that will pull behavior in the desired direction.
Creating a culture that will guide decision-making at every level of the organization requires a sustained systematic approach. Here are the five essential steps that boards must take:
Own the issue. The board must take ultimate responsibility for culture, rather than delegate it to a function like human resources. When culture is delegated, it becomes just another program among many. Such a fate recently befell a major player in the secondary mortgage market. Recognizing that its culture had accounted for many of the institution's problems during the financial crisis, it undertook what it thought would be a sweeping cultural transformation. But it turned responsibility over to the communications department, undercutting the organization's original ambition.
Culture also sometimes gets absorbed into branding and marketing instead of becoming a guiding principle. The result is an organization that pays lip service to grand ideals but generates cynicism among employees.
Lead by example. In word, and especially by deed, the board must set an example. A board that declares a customer-first culture but allows all of its decisions to be guided solely by a principle like "increasing shareholder value" will have its sincerity questioned by customers, employees, and regulators alike.
Cascade culture from the top down. Culture breaks down when different levels of the organization set different cultural agendas. Establishing a uniform culture starts with the chairman, whose first responsibility is to get the board aligned on the importance of culture and the principle that will guide it. The board, in turn, ensures that the chief executive makes culture a top priority with the members of the executive team, who then model it through their own behavior and influence teams to adopt and live the desired cultural values. In institutions where the chairman and CEO roles aren't split, the top-down effort can be even more focused, with the person who serves as chair and CEO guiding both the board and the executive team.
Define the desired cultural leadership attributes. Attributes like trustworthiness, a collaborative spirit and transparency may see them as difficult to define concretely and therefore impossible to gauge fairly. But in fact, well-governed institutions do precisely that when they consider CEO candidates, scoring them in such categories as judgment, authenticity, integrity, and more. A similar framework can be developed for cultural leadership. It can then be applied to the CEO and members of the executive committee and tied as objectively as possible to a portion of their compensation. Otherwise, the effort is likely to wither on the vine.
Monitor the progress of the organization. This requires clear, reliable indicators. A large regional bank, for example, wanted to establish a "high-performance" culture. They began by comparing the bank's valuation and employee engagement with that of its competitors and the financial services industry generally. (The Gallup organization has produced copious data establishing a correlation between valuation and employee engagement.) The bank found that its performance on both counts was sub-par. As the bank's cultural transformation goes forward, the board will monitor progress through, among other things, periodic assessments of employee engagement.
The benefits of a healthy culture are many, ranging from fewer unpleasant surprises to better performance and satisfied stakeholders. What's more, banks that systematically and comprehensively create a healthy culture will also be able to create healthier and more trusting relationships with regulators. And their boards can rest assured that they are exercising one of the now most widely recognized means of effective oversight: cultural stewardship.
Robert Sloan is co-managing partner of Park Avenue Advisors LLC. Dr. Leo Flanagan is the founder of The Center for Resilience.