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Behaviour and culture

The AFM supervises the behaviour and culture within financial enterprises. The culture within an organisation has a large influence on the behaviour of employees. Rules alone cannot cover all of the behaviour. Insight into behaviour and culture can help to signal supervision risks at an early stage.

Why conduct investigations into behaviour and culture?

The culture within an organisation largely determines the behaviour of employees. This is also the case in the financial sector. In addition to the many new rules that have been introduced, it is also important to look at the unwritten rules.

The AFM conducts investigations into behaviour and culture at financial enterprises. As a result, the AFM obtains better insight into what drives people to put the customer’s interest or public interest first. These insights make it possible to identify high risk behaviour before this has resulted in harm.

There is no blueprint for an 'ideal' culture. The AFM does not prescribe a specific culture, but provides insight into the risks that a culture could give rise to. On the one hand the AFM does this by conducting investigations and on the other hand by encouraging and enforcing financial enterprises to manage and control these risks.
Supervision of behaviour and culture is an addition to the regular supervision. The AFM's viewpoint is that a sustainable organisational culture is primarily the responsibility of the organisation itself.

How is an investigation into behaviour and culture conducted?

Guidelines have been developed for conducting an investigation with the aim of collecting data carefully and efficiently. This relates both to duration and to the burden placed on the organisation. The different phases of the investigation are described separately. See the link on this page.

These investigations can be carried out at all organisations that are subject to supervision by the AFM, such as larger and smaller banks and insurance companies, and also accounting firms, pension funds, investment firms and stock exchange platforms.

Which investigation methods are used?

Investigation of the organisational culture

The financial sector has paid a lot of attention to their products, services and processes in recent years. The customer's interests are often addressed in the mission, vision and core values. Nevertheless, this does not always result in the desired outcome for the customer. More insight is required in order to discover the root causes for this. A way to obtain that insight is to conduct an investigation into the organisational culture.

The link between the formulated policy and the ultimate results, are the employees in the organisation who have to take the decisions in daily practice. With an investigation into the organisational culture, we can obtain insight into what extent the customer's interests or the public's interests play a role within the organisation. More specifically, an investigation is conducted into which factors employees experience in their work that encourage or form an obstacle to putting the customer's interests first.

Investigation of capacity for change

An organisation's capacity for change is the degree in which groups of people within this organisation are willing and able to actually implement ambitions and plans and get these to work. Are the plans that are drawn up actually implemented?

The investigation of the capacity for change focuses on obtaining insight into both the patterns that form an obstacle for the success of a change and those that facilitate a change. To this end, a number of changes are investigated per organisation. These are changes that aim to promote the careful provision of financial services to customers.

The investigation does not give a qualitative assessment regarding the direction of the change, but examines how the change is implemented. The success factors and the obstacles that play a role in this. A positive example is a strong translation of the vision to the workforce by means of exemplary behaviour by the management. In contrast a negative example is insufficient elaboration of the change plan to the daily activities due to a lack of support and monitoring by the senior management.

Investigations at audit firms

We provide assistance to our colleagues on the supervision of audit firms for behaviour and culture investigations.

What is the added value of an investigation into behaviour and culture?

The insights from the investigations conducted by the AFM are of added value for both the enterprise and the AFM. The enterprise obtains insight into which patterns within its organisation influence the success of changes or act in the customer's interests. It can use these insights to improve its organisation. The AFM obtains insight into how changes and acting in the customer's interests work within specific organisations. This helps to understand an organisation better and thus to structure our ongoing supervision more efficiently.

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