Evidencing culture
and conduct.
Regulators, investors and non‑executive directors are now asking a harder question: “Show us what you actually see about culture and conduct, and what you do with it.”
Regulatory and Board Evidence Packs bring the main strands of Organisational Behavioural Economics together in one place, so boards can answer that question without relying on anecdotes, survey scores or generic “culture” slides.
They are built to sit naturally alongside risk, audit and compliance papers, making culture and behaviour part of how exposure, capital and governance are discussed rather than a parallel conversation.
What sits inside a pack.
Each pack combines four kinds of view that already exist across your organisation and market.
Signals in the wild - DCS Review
Monthly ten‑source reviews pull together external and social feedback - for example Glassdoor, Trustpilot, regulator reports and sector commentary - into patterns that show how your culture and conduct are already being experienced.
Position in the market - DCS Monitor
Quarterly benchmarking against “Top 50” firms in your sector shows whether themes are specific to you or sector‑wide, and whether your trajectory is converging with or diverging from peers facing similar pressures.
How the system behaves - Spectra, IRA & Shadow Ledger
Internal Resonance Audits look at artefacts, norms, informal and formal authorisations, mapped onto the Spectra and Organisational Capital Assets, with a Shadow Ledger that shows where dissonance is creating friction, losses and drag. This turns culture from atmosphere into priced exposure on the same page as financial and operational risk.
How it is governed - Integration & Alignment
Culture Risk Mapping shows how behavioural conditions amplify or dampen core risks. Governance Alignment tests whether structures, mandates and information flows make it realistic to oversee those risks. Integration with Compliance checks whether behaviour and culture sit inside the risk system, not beside it. Together, they show whether the system that produces behaviour is actually in scope for governance.
The pack does not introduce a new framework; it pulls these strands into a single, examinable bundle that a board, supervisor or investor can read as one story.
How boards and regulators use them.
For Boards
A pack is a way to:
- See culture risk alongside principal risks, appetite and capital discussions, rather than in a people section.
- Test whether governance, decision‑rights and incentives match the exposures they have chosen to run.
- Ask whether compliance and assurance work reflects how people actually behave around rules, not just whether rules exist.
For Regulators and Investors
A pack provides:
- Traceable links from observed behaviour and stakeholder experience to risk types, control themes and governance responses.
- A way to see whether culture insights were known, understood and acted on, rather than left as commentary around a formally compliant system.
- A map between the Spectra and sector codes (for example SRA, FCA, PRA, ICO, PSA, OfS), showing how specific cultural states relate to explicit regulatory expectations.
In effect, the pack becomes the answer to “what should this board reasonably have known, and what did it do with that knowledge?”
If you cannot show this.
When serious incidents or thematic reviews land, regulators increasingly ask what the board already knew about cultural conditions and what it did with that knowledge.
Where there is no coherent view - no culture risk map, no governance‑alignment lens, no integration between culture insight and compliance - boards can look formally diligent yet are judged to have relied on atmosphere and reassurance rather than evidence.
In that position, findings tend to focus on failures of governance and oversight, not just individual misconduct, because behavioural risk was visible in parts of the system but not brought into board view.
How the packs are assembled.
Evidence Packs are assembled as part of advisory work that already uses OBE across intelligence, risk and governance. We work with boards, committees and senior executives to:
- Pull existing DCS, Spectra, Shadow Ledger, culture‑risk and governance‑alignment work into one coherent set of materials.
- Fill specific gaps where regulators or investors would expect clearer linkage, for example between culture risk maps and risk appetite, or between whistleblowing and compliance planning.
- Document the line from evidence to challenge to action, so oversight can be shown as an ongoing practice rather than a one‑off initiative.
Over time, these packs can become a standing part of your board cycle, refreshed as the DCS Review, DCS Monitor and internal work evolve.
Support for regulatory requests and investigations.
For some organisations, the first interaction with this work is not a planned cycle but a letter from a regulator.
We support boards, executives and in‑house teams to assemble and interpret culture‑related evidence in response to supervisory questions, investigations or independent reviews. The same instruments - DCS Review and Monitor, Spectra, Shadow Ledger, culture risk maps, governance alignment and integration with compliance - are used to read what the organisation already knows about behaviour and exposure.
This is not legal defence or PR. It is about making sure that, when regulators ask what you saw, how you joined it up, and what changed as a result, you can show a coherent line from signals to challenge to action rather than a set of disconnected documents.