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GRC Professional : GRC Spring 2012
13 There are three elements involved in influencing people's behaviour and thinking in the workplace, she says The first is leaders' behaviour. Junior staff receive a message they will be successful if they behave as leaders do. If leaders are behaving unethically, other staff understand if they behave the same way, they too will rise through the ranks. The second is that high-risk behaviour will flourish if business systems such as performance management frameworks encourage it. The third element is symbols. "People look for clues as to how to behave and if someone's behaviour is not risk-appropriate, but they are promoted, the message is that's ok," Wakefield says. AMP Capital's Monika Goyal, head of enterprise risk management, says it's possible to maintain an ethical culture within an organisation whose main mission is to make money. "Achieving returns for our investors and unethical behaviour are not mutually exclusive. "It is important companies reward traders who deliver good returns as long as ethical behaviour is practised. "Should a trader demonstrate unethical behaviour, the company should implement disciplina ry actions including remuneration impacts," she says. Code of conduct Goyal says the starting point for ensuring ethical behaviour is AMP Capital's code of conduct. "A number of additional policies and practices need to be in place, including the management of conflicts of interest, personal trading, and maintenance of information barriers. From here, it is important to monitor compliance with these policies and practices, with instances of non-compliance having a disciplinary impact." Goyal says there are other steps financial services businesses can put in place to reduce the risk of unethical behaviour. These include ensuring the code of conduct is communicated across the organisation. ••• Your legal compliance training solution. One click away.
GRC Winter 2012
GRC Summer 2013