Assessment Results2017

OVERVIEW OF THE BSB ASSESSMENT

The BSB’s Assessment and policy work are intended to provide member firms with the evidence, support and challenge to help them achieve and maintain high standards of behaviour and competence, individually and collectively. Underpinning this dual approach is a framework of nine characteristics, both ethical and professional, that we would expect to lead to good outcomes for customers, members, clients, employees or investors and the economy and society as a whole; characteristics that we would therefore expect to be associated with any good culture in banking.

Our Assessment does not assess firms against a template of what a ‘good’ culture looks like. There is no uniquely good (or bad) organisational culture against which all others can be measured. Firms with very different cultures can produce equally good or bad outcomes for customers and clients and more broadly.

We do not, therefore, set out to measure or rank culture directly. Rather, we ask how far each of our nine characteristics is demonstrated by the firm and relative to other firms. We would expect a firm that strongly exhibited our nine characteristics to be better equipped and more likely to service its customers, members and clients well, than one in which these elements were lacking.

The nine characteristics against which firms are assessed are honesty, respect, openness, accountability, competence, reliability, responsiveness, personal and organisational resilience, and shared purpose.

Shared Purpose

If these characteristics appear obvious and fundamental, that is precisely as it should be. They are characteristics that customers, members or clients should be able to take for granted as being not only present, but present to a very high degree in any bank or building society that they entrust their money to or deal with, irrespective of the firm’s size, business model, market segment, age, ownership structure or location. Furthermore, given the importance of the banking sector to the economy and the systemic nature of the sector, the public as a whole also has the right to expect the same of every bank or building society operating in the UK, whether or not they engage with it personally and directly.

Assessing firms against our nine characteristics and exploring areas of both strength and weakness, reveals issues relevant to both individual firms and to firms collectively. At the individual firm level, the results of the Assessment are given to each board and discussed with the firm. The BSB does not publish firms’ Assessment reports. It is the responsibility of each board and executive team to decide how to act on and share (e.g. with employees and regulators) the contents of their report.

Members firms join the BSB and engage in the Assessment in order to learn and continuously improve. Participation in the Assessment, with its cross-firm benchmarking and detailed reporting, demands a readiness on the part of board members and the executives to be self-critical and to ask questions of themselves and their employees that may elicit unexpected and unwelcome answers. A far more comfortable option would be to avoid asking such questions in the first place. BSB membership is voluntary; it is also challenging.

While individual firm reports are owned by the firms concerned, the BSB is committed to publishing evidence of what it finds at the cross-firm level, and identifying the issues and themes that in turn inform its policy work.

The Assessment exercise asks how far the nine characteristics of the BSB framework are demonstrated within a firm. Repeated annually, it provides boards with an impartial, evidence-based picture of the culture of their firm; not only over time and across different business areas, but also relative to other firms. These multiple perspectives, combined with other internal and external data used by firms, equip boards and executive teams better to gauge progress, set priorities and learn from good practice both within the firm and (including through our policy work) across firms.

The Assessment approach was developed by the BSB, working with leading academics in the fields of organisational psychology and ethnography from the London Business School and the London School of Economics and with strategy consultants. It comprises both a quantitative element (generated from an employee Survey) and a qualitative dimension (including e.g. focus groups, interviews and board questions) that allows the Survey results and any broader themes to be explored in more detail. All participating firms engage in the Survey, the data from which provides benchmarked results by firm and business area.

Each firm receives its own Survey results, including (assuming that response rates were high enough to be statistically representative of the relevant populations, and, where at least seven firms could be compared) a comparison of its scores on each characteristic and question, with the range of scores of all participating firms. These comparisons are provided not only at firm level, but also (where relevant to the firm) for retail banking, investment banking and functions, and at the next level down (e.g. within retail banking, for retail branch, private banking, commercial banking etc).

Comparisons in each case include a range and quartile against the equivalent category across all relevant firms, though without revealing the identify of any individual firm. The results for retail banking at Firm A, for example, were compared with those for retail banking at all assessed firms with a retail banking business.

Firms that take part in both the Survey and the qualitative elements of the full Assessment receive a more extensive report containing fuller findings and analysis.

We continue to explore new measurement techniques, as well as whether and how to incorporate firm or third-party information into the Assessment, to ensure that the exercise remains valuable for firms and for their customers, members, clients and employees.

2017 SURVEY PARTICIPANTS

36

,

268
survey responses
761
members of staff interviewed in 87 focus groups
25
firms surveyed
60
executive interviews
11
firms fully assessed
11
non-executive interviews

In 2017 the BSB conducted its second full Assessment. 25 member firms took part in the 2017 exercise, up from 22 in 2016. Of these, 11 participated in the full Assessment exercise (both quantitative and qualitative), with 14 taking part in the Survey component only. The firms that took part in the Assessment are listed below, with the firms that participated in the full Assessment exercise (both qualitative and quantitative) highlighted in bold.

Aldermore, Bank of Ireland, Barclays, Buckinghamshire Building Society, Cambridge and Counties Bank, Charity Bank, Citi, Co-op, CYBG, Ecology, Handelsbanken, HSBC, Ipswich Building Society, Lloyds Banking Group, Morgan Stanley, Nationwide, OneSavings Bank, Paragon Bank, Penrith Building Society, RBS, Santander, Standard Chartered, State Bank of India, Tesco Bank, Unity Trust Bank

BSB EMPLOYEE SURVEY

HONESTY
  1. I believe senior leaders in my organisation mean what they say.
  2. In my organisation I see instances where unethical behaviour is rewarded.
  3. My colleagues act in an honest and ethical way.
  4. It is difficult to make careerprogression in my organisation without flexing my ethical standards.
RESPECT
  1. At my work I feel that I am treated with respect.
  2. At my work people seek and respect different opinions when making decisions.
  3. In my organisation Risk and Compliance are both respected functions.
  4. In my organisation we are encouraged to follow the spirit of the rules (what they mean, not just the words).
  5. I believe my organisation puts customers at the centre of business decisions.
OPENNESS
  1. In my experience, people in my organisation are truly open to review and feedback from external sources.
  2. In my organisation people are encouraged to provide customers with information in a way that helps them make the right decisions.
  3. In my experience, people in my organisation do not get defensive when their views are challenged by colleagues.
  4. In my organisation I am encouraged to share learnings and good practices with others.
  5. If I raised concerns about the way we work, I would be worried about the negative consequences for me.
ACCOUNTABILITY
  1. In my experience, people in my area clearly understand the behaviour that is expected of them.1
  2. I believe senior leaders in my organisation take responsibility, especially if things go wrong.
  3. I see people in my organisation turn a blind eye to inappropriate behaviour.
  4. I see people in my organisation try to avoid responsibility in case something goes wrong.2
  5. I feel comfortable challenging a decision made by my manager.
COMPETENCE
  1. In my experience, people in my organisation have the skills and knowledge to do their jobs well.
  2. In my role, I am encouraged to continually learn new skills and improve my role-specific knowledge.
  3. I am confident in the ability of people in my area to identify risks.3
RELIABILITY
  1. When my organisation says it will do something for customers, it gets done.
  2. I see the people I work with go the extra mile in order to meet the needs of our customers.
  3. When people in my organisation say they will do something, I can rely on them getting it done.
RESILIENCE
  1. In my experience, people in my organisation are good at dealing with issues before they become major problems.
  2. My organisation focuses primarily on short term results.
  3. I often feel under excessive pressure to perform in my work . 4
  4. Working in my organisation has a negative impact on my health and well-being.
RESPONSIVENESS
  1. I believe that my organisation responds effectively to staff feedback.
  2. Our internal processes and practices are a barrier to our continuous improvement.
  3. I believe that my organisation responds effectively to customer feedback.
  4. I believe that my organisation encourages innovation in the best interests of our customers.
  5. I have observed improvements in the way we do things based on lessons learnt.
SHARED PURPOSE
  1. My organisation’s purpose and values are meaningful to me.
  2. There is no conflict between my organisation’s stated values and how we do business.

The BSB Employee Survey consists of 37 core questions. Questions 1-36 each correspond to one of the nine characteristics of the Assessment framework. Question 37, is a free text box asking respondents to enter three words describing their firm. The questions explore employees’ perceptions, observations and beliefs about their firm’s culture, drawing on personal experience. Questions are both positively and negatively framed to reduce the risk of acquiescence bias (the tendency of survey participants to agree with questions). In developing and refining the survey we conducted cognitive testing with a number of employees across business lines at a diverse set of firms.

The Survey is run in each firm on a consistent, stand-alone basis to avoid firm-specific framing effects that might bias answers, and provides statistically representative results to firms across different business lines and functions. Employees completing the Survey do so completely anonymously and results are presented in a way that avoids any risk of attribution.

Questions 1-36 of the survey use a five-point Likert scale, i.e.: Strongly Agree, Somewhat Agree, Neither Agree nor Disagree, Somewhat Disagree, Strongly Disagree. To compare results across firms, we convert answers on these into scores on a scale of 0 to 100, for both questions on their own, and when they are grouped into the nine characteristics.

We sample the Survey at the level of individual business lines and functions. While this allows us to run the Survey on a sample basis, some firms, and more so increasingly choose to run it on a census (i.e. whole firm) basis. Our sampling approach is designed to provide statistically representative results to firms at individual business lines and functions, and benchmark comparable areas of different firms.

Each firm receives its own Survey results, including comparisons of its scores on each characteristic and each question against a benchmark made up of all participating firms.

We provide firms with comparisons of their Survey results at different levels, on an interactive dashboard. Firms are able to see the Survey score for their whole organisation, with a rank and quartile position compared to other participating firms. They also see individual scores for each of their business lines and functions, benchmarked against all other firms with comparable business areas. They are able to cut the data by demographics, with strict rules in place to avoid any risk of attribution.

With their results displayed in this way, boards and executive teams can see specifically where they are performing well against their peers, and where there is room for progress. Repeating this annually, using the same methodology, allows them to also gauge progress over time.

The consistency of the Survey questions (and the nine characteristics of the underlying framework) is central to enabling a dynamic picture to be built up over time, both at and within individual firms and across firms. The qualitative aspect of the Assessment may, in contrast, vary from year to year depending on the themes explore and the most appropriate way of approaching these.

In 2017, we amended a very small number of questions to reflect our learning from the first year of having run the Survey. Where questions are amended, this is always made clear to avoid incorrect comparisons being drawn. We also asked, in 2017, an additional three questions exploring specific themes

In 2017 we sent the survey to 106,092 individuals at 25 firms, and received 36,268 responses. In 2016 we had sent the survey to 82,139 individuals at 22 firms, and received 28,122 responses.

CHANGES TO THE SURVEY IN 20175

We modified four questions in the main body of the Survey after learning from the exercise, which was run for the first time in 2016. While changes in scores on these questions from 2016 and 2017 might in part reflect changes in the perceptions and observations of their employees, they may also reflect the modified framing of these questions.

Original question in 2016 Survey Rationale for change Revised question for 2017 Survey
Q15. I clearly understand the behaviour that is expected of me Possible illusory superiority bias (individuals overestimating their own qualities and abilities) Q15. In my experience, people in my area clearly understand the behaviour expected of them
Q18. I see people in my organisation try to pass responsibility to others in case things go wrong Clarity Q18. I see people in my organisation try to avoid responsibility in case something goes wrong
Q22. I feel confident in my ability to identify risks in my area Possible illusory superiority bias (individuals overestimating their own qualities and abilities) Q22. I am confident in the ability of people in my area to identify risks
Q28. I often feel under considerable pressure to perform in my work This question relates to personal resilience. While some degree of pressure may be good, in this context we are particularly interested in excessive pressure Q28. I often feel under excessive pressure to perform in my work

GATHERING QUALITATIVE EVIDENCE

For firms that take part in the full Assessment, we gather additional, qualitative evidence. We use this evidence, together with Survey scores and benchmarks, to produce independent and objective reports for the boards of firms.

There are three main ways in which we gather qualitative evidence.

Board questionnaires

In both 2016 and in 2017, the BSB Chairman wrote to the Chairs of each participating firm. In 2017 the following questions were asked:

  • What are your priorities on culture, behaviour and competence over the coming twelve months, and which do you expect to be the most difficult to achieve? Have these changed since 2016, and if so, why?
  • How will you be judging progress against your objectives?
  • Is there any additional contextual information which you feel is relevant in the assessment of culture, behaviour and competence at your firm?

Board and Executive interviews

We interviewed 60 executives and 11 non-executive directors (NEDs) across the 11 firms participating in the full Assessment in 2017. This followed interviews with 114 executives and 26 NEDs across 14 firms taking part in the full Assessment in 2016. Interviews were semi-structured and covered:

  • culture changes at the firm during the previous 12 months;
  • priorities over the next 12 months;
  • in 2017 questions relating to the themes from the 2016 Assessment, see Annual Review 2016/2017; and
  • any other cultural or behavioural topics that the interviewee wished to discuss.

These interviews help us to understand individual board member and executives’ perspectives on their organisation, along with a sense of what they feel is going well and what if anything they feel needs to change. We use these perspectives to inform our Assessment report that each board receives for its firm.

Focus Groups

We run focus groups with junior and middle-ranking employees to discuss their organisation’s culture. In 2017, we also used these focus groups to explore three themes that had emerged from our findings in 2016, see the Annual Review 2016/2017.

Our focus groups contain a mixture of levels of seniority, and we always ask that no participant’s line manager be part of the same focus group. We conducted 87 focus groups in 2017, involving more than 750 employees across the 11 firms taking part in the full Assessment. These followed 104 focus groups in 2016, involving more than 800 employees. Participants were drawn from teams across different business lines and functions.

The feedback that we receive from focus groups is often extremely detailed and rich, containing valuable insights on a range of issues that relate to culture, behaviour and competence at individual firms, and across the banking industry.

The BSB does not hold any information on the identities of the individuals who participate in the sessions, but analyses the feedback to produce firms’ Assessment reports and in developing the findings in our Annual Review.

BSB SURVEY: 2017 DESCRIPTIVE STATISTICS

2017 RESPONSES BREAKDOWN BY BUSINESS AREA
2017 RESPONSES BREAKDOWN BY DETAILED BUSINESS AREA
2017 RESPONSES BREAKDOWN BY DETAILED BUSINESS AREA
2017 RESPONSES – BREAKDOWN BY LOCATION

NEXT SECTION: RESULTS

Senior Managers and Certification Regime

Exploring how the SMCR - and especially Certification - can be implemented in the most effective way across the sector.

The Senior Managers and Certification Regime is a major regulatory change that will affect all banks and building societies. Responding to recommendations by the Parliamentary Commission on Banking Standards, the government and regulators have together developed a comprehensive framework to ensure better accountability and responsibility for behaviour, competence and culture in banks and building societies. The new framework provides an opportunity for the industry to focus on and demonstrate a culture of professionalism. We are working with firms and regulators to facilitate this, including areas where a common approach across firms could support both the objectives of the regime and the skills and development of the people covered by it.

Professionalism

Evaluating whether a more 'professional' approach to banking would improve behaviour and competence across the industry.

The Parliamentary Commission on Banking Standards found that 'banking culture has all too often been characterised by an absence of any sense of collective responsibility to uphold the reputation of the industry', and argued that a greater focus on professionalism could be an answer to this. Working with a leading team at the University of Leeds, we are researching the issues around professionalism in banking. In particular, we are reviewing how professional qualifications are currently used across the sector, and at whether a stronger role for professional bodies, along the lines seen in some other sectors, like medicine or law, would help raise standards. To inform this work and develop a rounded picture of 'professionalism' and what it means in banking, we are surveying banks and building societies, professional bodies and a wide range of other interested groups, including consumer bodies and investors.

Assessments

Providing an honest and impartial assessment to Boards of progress against objectives on behaviour, competence and culture.

The BSB assessment exercise presents Boards with an objective and impartial view of their firm's culture, identifying where things are working well and recommending areas for improvement. It draws on information not only from Boards and senior teams, but also from employees, investors (or members), trade unions, customer groups and other relevant bodies. In doing so, it will provide constructive challenge to each firm individually, while building a collective understanding of common issues across the industry, or sectors within it. We undertook our first annual assessment exercise in 2015 with ten firms (Barclays, Citi, HSBC Bank, Lloyds Banking Group, Metro Bank, Morgan Stanley International, Nationwide, RBS, Santander UK and Standard Chartered). The BSB itself will not publish individual assessment reports - each firm owns its own report - but key themes and messages will be set out in the BSB's annual report, the first of which will be published in Spring 2016. Given that Board engagement is central to the assessment work, only firms that have their headquarters in the UK are eligible for the full assessment exercise. All firms, including branches of firms headquartered overseas, will however be included in a focused membership-wide survey, which will allow each participating firm to benchmark itself against its peer group.

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