Upon completion of this course, participants will be able to:

• Define conduct risk and understand its sources, including conflicts of interest, ethical lapses, and poor product design.
• Assess the current state of the organization's **Risk Culture** using structured diagnostic tools.
• Identify and manage key behavioral drivers of misconduct (e.g., perverse incentives, pressure, lack of accountability).
• Develop and implement a clear, principles-based **Code of Conduct** and ethics policy.
• Design effective training and communication programs to embed expected behaviors across the firm.
• Establish robust metrics and **Key Behavioral Indicators (KBIs)** to monitor conduct risk trends.
• Understand the role of compensation and performance management in driving or deterring misconduct.
• Design a fair and consistent disciplinary process for addressing breaches of the code of conduct.

• Senior Executives and Board Members
• Heads of HR and Organizational Development
• Compliance, Ethics, and Internal Audit Professionals
• Risk Managers focusing on non-financial risk
• Legal and Regulatory Affairs Specialists

• Group Risk Culture Assessment Workshop and KBI Definition
• Case Studies on Major Mis-selling and Culture-Driven Failures (e.g., LIBOR scandal)
• Individual Exercise: Redesigning an Incentive Scheme to Remove Perverse Incentives
• Role-Playing Ethical Dilemma and Disciplinary Review Scenarios
• Discussions on the Philosophical and Psychological Roots of Misconduct

Unit 1: The Landscape of Conduct Risk

• Defining conduct risk and the regulatory focus on treating customers fairly (TCF) and market integrity.
• Understanding the severe financial and reputational consequences of major conduct failures.
• The difference between rules-based compliance and principles-based conduct risk management.
• Key areas of focus: conflicts of interest, unethical sales practices, and market manipulation.
• Analyzing the influence of organizational structure and tone-at-the-top on employee behavior.

Unit 2: Assessing Risk Culture

• Methodologies for conducting an organization-wide **Risk Culture Assessment** (surveys, focus groups, interviews).
• Identifying the key cultural attributes that either promote or hinder ethical conduct.
• Designing and utilizing **Key Behavioral Indicators (KBIs)** and cultural metrics for monitoring.
• Analyzing internal data (e.g., whistleblowing reports, audit findings, staff turnover) for conduct patterns.
• The role of the Board and senior management in setting and modeling the desired culture.

Unit 3: Governance and Control Implementation

• Developing a clear, easy-to-understand **Code of Conduct** and ethics policy.
• Designing processes to manage and mitigate conflicts of interest (e.g., disclosures, firewalls).
• Reviewing and realigning employee compensation and incentive structures to remove perverse incentives.
• Implementing mandatory training on conduct, ethics, and specific risk behaviors.
• The role of non-financial metrics in performance reviews and accountability.

Unit 4: Monitoring and Proactive Management

• Establishing a robust supervisory framework to monitor employee conduct in high-risk areas (e.g., trading).
• Using technology to monitor communication and transaction patterns for signs of misconduct.
• Developing a fair, transparent, and consistent disciplinary and sanctioning process.
• Managing "speaking up" mechanisms and ensuring non-retaliation policies are effective.
• Protocols for investigating and resolving conduct breaches and ethical dilemmas.

Unit 5: Driving Cultural Change

• Strategies for driving sustainable change in risk culture over the long term.
• Techniques for making ethical principles relatable and actionable for frontline staff.
• Conducting regular "deep dives" on culture and conduct in specific business units.
• Integrating culture and conduct assessment into M&A due diligence and integration.
• Reporting progress on culture and conduct risk initiatives to regulatory bodies.