b'TABLE OF CONTENTSCulture On July 7, 2021, the FCA, PRA and Bank of England (the regulators) announced that they are seeking Diversity is becoming an increasingly importantviews on regulatory plans to improve diversity and factor in the thinking of UK regulators. They seeinclusion in financial services.diversity as a driver of good culture, including inIn a discussion paper, the regulators set out policy particular a good speak up culture whichoptions including, among others, the use of targets promotes challenges, which in turn promotes afor representation, measures to make senior leaders compliant culture.directly accountable for diversity and inclusion in The FCA Business Plan 2021/2022 (the Businesstheir firms, linking remuneration to diversity and Plan) includes diversity and inclusion as a cross- inclusion metrics and the regulators approach to sector priority. The Business Plan explains theconsidering diversity and inclusion in non-financial importance of diversity and inclusion to the regulator:misconduct. The discussion paper also focuses on the importance of data and disclosure in order to Our ambition is to ensure the financial systemenable firms, regulators and other stakeholders to supports the economy through well-run firmsmonitor progress. and sound financial markets that can meet the diverse needs of their consumers. Firms thatThe regulators believe that increased diversity and represent the society they serve support theinclusion will advance their statutory objectives by design of financial services and products thatresulting in improved governance, decision-making improve consumer outcomes. We want aand risk management within firms, a more resilient financial services sector, which bringsinnovative industry, and products and services together and responds to different perspectivesbetter suited to the diverse needs of consumers.so concerns are raised and decisions challengedA representative of the FCA stated in a speech on effectively. An inclusive culture in which all staffSeptember 24, 2021, entitled A regulatory can speak up allows conduct risk to beperspective: measuring and assessing culture, now managed. Together, diversity and inclusion canand in the future, the role of purpose and the reduce groupthink, encourage debate andimportance of D&I: innovation and so improve outcomes for consumers and across markets.We measure and assess a firms culture against four drivers of culture: purpose, people, The outcomes the FCA seeks to achieve in relationleadership and governance. This covers a wide to diversity and inclusion are that regulated firmsrange of areasto list but a few it could include: and listed companies have more diversesignificant business model restructures, the representation at all levels, foster cultures that areapproach to remuneration, speak-up culture, inclusive so that staff can share their diverseBoard and ExCo composition, diversity, experiences and backgrounds and firms design andsuccession planning, the application of the deliver products that reflect the diverse needs ofSMCR, the effectiveness of a firms controls consumers, offer fair value and are delivered in aenvironment or its governance structures.fair andaccessible way.MAYER BROWN |105'