As the sector reflects on the FCA's latest policy statement, PS25/23 Tackling Non-Financial Misconduct in Financial Services, one theme is becoming impossible to ignore: culture is no longer a soft concept or an HR side initiative. It is now a regulatory imperative.
For insurance brokers and financial services firms, this marks a pivotal shift. Non-financial misconduct, including bullying, harassment, discrimination and exclusionary behaviours, is now firmly recognised as a matter of conduct risk, governance oversight and organisational integrity. The FCA has made it clear that culture is a core driver of performance and how leaders shape, monitor and respond to culture now sits at the heart of regulatory expectations.
What resonated most for many leaders was a simple truth: you cannot manage what you cannot measure. When culture goes unmeasured, risks go unnoticed. When risks go unnoticed, harm becomes inevitable.
Culture as a governance priority
PS25/23 reinforces what many have known intuitively for years, that behavioural risk is business risk. The FCA has moved decisively to embed non-financial misconduct within Conduct Rules and Fit and Proper assessments, signalling that firms must demonstrate a culture where employees are psychologically safe, valued and heard.
The message is clear: compliance is no longer limited to systems and controls. It extends to how people are treated, how decisions are made and how leaders shape the lived experience of work. Boards and CEOs can no longer rely on policy statements or annual engagement surveys as evidence of culture. Policies may set intent, but behaviour speaks louder than documents.
When you can measure culture, you can shape it. When you can shape it, you can govern it.
From optics to impact
A recurring concern among leaders: many organisations still approach culture through activity rather than impact. Awards, events, slogans and training can create the appearance of progress, but without evidence of change, they risk being little more than cultural theatre. The FCA's stance eliminates the space for ambiguity.
Culture can remain a blind spot if leaders cannot answer how safe people feel to speak up, who thrives and who does not, which groups experience risk or exclusion and how behaviours align with stated values. Blind spots are where regulatory breaches, reputational damage and misconduct thrive.
Measuring culture: from intangible to essential
This is where culture measurement moves from intangible concept to essential governance practice. When leaders understand culture through evidence, through sentiment, behaviour, trust levels and inclusion dynamics, they can act with confidence and accountability. They can identify risk before it becomes harm and see which interventions work and which do not.
Built on eight years of research and validated by thousands of employees, Kintris's Scientific Culture and Benchmarking Framework offers an evidence-based approach to understanding people, their culture experience and psychological safety. With five core culture metrics, 17 sub-dimensions and 57 data points, it provides leaders what was previously missing: a measurable, comparative and credible understanding of the lived culture across their organisation, with sector benchmarks and one-click regulatory reporting for FCA compliance.
Final reflections
Peter Drucker's line that culture eats strategy for breakfast has never been more relevant. Strategy cannot thrive in environments where people feel unsafe, excluded or unheard and now regulators are holding leaders accountable for the cultural environments they create.
PS25/23 signals a future where culture, conduct and governance converge, where employee experience becomes a matter of organisational integrity and where Boards must take a proactive and deliberate stance on shaping culture as a driver of trust, innovation and sustainable performance. The opportunity and responsibility now sits firmly with leadership.