We expect all our employees to perform their roles to the highest ethical standards, which we outline in our Code of Conduct. To support this, we are strengthening and embedding our risk culture throughout our organisation.

A risk culture encompasses the values, behaviour and attitudes of an organisation’s people, influencing how that organisation perceives and manages risk. Weaknesses in companies’ risk cultures were a root cause of the financial crisis. Having a strong risk culture is critical in ensuring that ‘doing the right thing’ wins over ‘doing whatever it takes’.


We have a network of 70 risk champions in Europe, the Middle East and Africa (EMEA). One of their key objectives is to foster a culture that meets our own corporate values, supporting the principles of ‘doing what’s right’ (a central requirement of our Code of Conduct), as well as meeting our regulators’ expectations.

As part of their role, our risk champions embed best practice and recommendations within their area of the business. They also share challenges and lessons learned, and co-ordinate training, workshops and discussions.

Recognising the value of in-person training, we have developed a series of interactive workshops, focused on ethical dilemmas. The workshops reflect the fact that while rules and regulations can clearly state what behaviour is acceptable, ethics are often open to interpretation. The workshops therefore focus on the ethical issues we sometimes face in our day-to-day work. They encourage open discussion and debate, reinforce appropriate behaviours and give our people a better understanding of our risk environment.


By September 2018, we had delivered nearly 60 ethical dilemma sessions to middle management in EMEA and India, with nearly 1,300 people attending. The feedback from attendees has been overwhelmingly positive, with typical comments including:

‘These sessions are very thought provoking and work great as a refresher, in comparison to on-screen modules.’

‘I would highly recommend the workshop to anyone who values interactive and lively debate on challenging issues!’

‘I found the session really fun and engaging, especially as we were encouraged to answer honestly and not just give the textbook answer that we thought we should. It was also really interesting to hear about other people’s personal ethical dilemmas that they’ve found themselves in!’

Key lesson

Using scenarios in training is very effective in bringing ethics, trust and behaviours to life. Providing an opportunity to share views and lessons learned and debate ethical dilemmas allows participants to talk through any potential problems and dilemmas they may face.

The workshops also help us to drive a culture of openness and accountability, where employees are encouraged to speak up and challenge misconduct or identify ethical dilemmas in their day-to-day work.