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Abi Olapade

Abi Olapade, Principal Consultant and Specialist in Regulatory Compliance, GFT

Abi Olapade

Abi Olapade

When I first considered the significance and impact that the Senior Management Regime (SMR) would have on banking standards, I immediately thought of the words of King Henry IV from Shakespeare’s Henry IV, Part II: “Uneasy lies the head that wears the crown”. Is there a more apt line to describe how many senior managers must now be feeling with the introduction of SMR?

SMR can be seen as a dramatic new step in banking regulation, with the onus on taking a more individually accountable approach. The devastating effects of the most recent financial crisis revealed a culture where many senior managers operated in an environment where there was a distinct lack of personal accountability. The result is that nearly 8 years after the financial crisis, which resulted in enormous global consequences, very few individuals have actually faced charges – a point which has resulted in understandable anger from both members of the public and politicians.

The introduction of SMR is about ensuring this never happens again in the UK.

SMR came into force on 7th March 2016, initially for UK banks (including incoming EEA and third country foreign branches), building societies, credit unions and PRA regulated investment firms. The regime will later be extended to cover all FSMA regulated firms by 2018.

The Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) are enforcing SMR alongside the Certificate Regime (CR) and associated Conduct Rules as part of the “Strengthening Accountability in Banking” policies, which aim to achieve consistent good conduct across the whole of the UK Financial Services industry.

Under the SMR, senior managers will have a statutory duty of responsibility to take reasonable steps to prevent regulatory breaches in their area of responsibility.  Furthermore, each Senior Manager’s area of responsibility is to be made much more explicit.

With the regime now in force, senior managers should have been mapped to one or more of the 17 Senior Management Functions (SMFs) that have been defined. The specific responsibilities of each individual must have also been clearly described (ideally in 300 words or less) in a ‘Statement of Responsibility’. Firms are also expected to have produced overall ‘Management Responsibility Maps’ which describe the structure, size and complexity of the firm, including management and governance arrangements.

Under the accompanying Certification Regime, firms are required to have identified (but not register) non SMF individuals who are in a certified / material risk taking / significant harm function by the 7th March 2016 enforcement date. Firms are also expected to put procedures in place to assess the “fitness and proprietary” levels of these (as well as SMF) individuals. Firms had until 7th March 2017 to complete the initial assessments and will be required to perform these assessments on an annual basis going forward.

The SMR Conduct Rules set out a basic standard for behaviour which all those covered by the SMR and CR are expected to meet; firms are required to ensure that all identified SMR and CR individuals are made aware of the Conduct Rules, how they apply to them individually, and that they are subject to these rules from 7th March 2016 onwards. Similarly, non SMR / CR staff will need to be made aware of the Conduct Rules and the fact that they will be subject to these Conduct Rules from 7th March 2017.

It is easy to see why the SMR is causing a great deal of concern amongst senior managers throughout the City. The stakes have been raised with senior managers and key non-executive directors now at risk of receiving personal heavy fines or bans from the industry if they cannot show that they have taken reasonable steps to prevent wrongdoing and unethical behaviour within their areas of responsibility.

In an eleventh hour move, the government decided to replace the originally stated ‘reverse burden of proof’ with a ‘statutory duty of responsibility’ on individuals. This change has been seen by some critics as a government back track, such that in the case of any potential misconduct, the regulator (not the individual) will have to prove that the individual had not taken reasonable steps to ensure that the business was run properly. The regulator would need to show that in their area of responsibility, the individual had not implemented operating procedures and systems to comply with the relevant regulatory requirements.

Nevertheless, the SMR and any related enforcements are likely to be seen as feathers in UK Chancellor George Osborne’s cap of reforming Britain’s banking regulation, in order to help build a stronger and safer financial system. He is quoted as saying that the SMR is introducing “new rules that mean individuals working in UK firms face some of the toughest sanctions in the world.”

On this basis, I think it is safe to assume that it will not be too long before both enforcement regulators – the FCA and PRA – begin knocking on firm’s doors to assess their compliance to the new regime.

So what are the regulators likely to look for in an SMR assessment visit?

In addition to verifying that the organisational and governance structures required under SMR have been put in place, the focus is likely to be on evidence that senior managers in senior management functions have a true understanding of the overall risks relating to the area(s) that they are responsible for.

Senior managers need to actively demonstrate that they have their finger on the regulatory compliance pulse for their areas of responsibility and that they are fully aware and in control of all the regulatory risk and issues relating to these functional areas. The implementation status of related roadmaps, plans or steps required to mitigate or remediate any risks or issues (whether they are related to data, systems / technology or operational control activities) are things that regulators are likely to expect senior managers to have at their fingertips.

The ability to clearly and factually state an overall view of compliance to key regulations such as CFTC, EMIR, MIFID I, AMLD, BCBS239 and PSD is almost certainly something regulators will expect senior managers to have to hand.

Furthermore, Regulators are likely to expect senior managers to have a forward looking view and an awareness of incoming regulatory changes that may impact their areas of responsibility.

The ‘reverse burden of proof’ may have been abandoned, but senior managers need to consider how they can clearly demonstrate the monitoring and oversight of their specific areas of responsibility. A regulatory management tool will allow senior managers within firms to refute claims from regulators that appropriate governance and monitoring have not been taking place.

GFT has invested in creating such a tool, the GFT Regulatory Change Manager that can provide a regulatory overview for senior managers, which also helps them provide evidence and demonstrate accountability and compliance in response to questions from a regulator.


Fig 1- GFT Regulatory Change Manager: Example Compliance Oversight Senior Manager’s view


Fig 2 – GFT Regulatory Change Manager: Example Overall Responsibility Senior Manager’s view


Fig 3 – GFT Regulatory Change Manager: Example Compliance Oversight Senior Manager’s view (Functional)

When we consider the dramatic mistakes made in the past, firms and managers must now firmly understand the risks they are taking on a day-to-day basis; and be able to demonstrate that they are adequately managing those risks. SMR should be seen as a wakeup call to senior managers that regulators expect them to be doing this on an active – or more accurately – on a proactive basis. The ability to monitor their responsibilities using a regulatory management tool should help senior managers identify and take action to address any risks or issues as and when (or before) they arise.

Individuals working in UK financial services firms now face some of the toughest sanctions in the industry worldwide. If trust and confidence in UK financial services is to be restored such measures are necessary, but the increased pressure on senior managers should not be underestimated.

It is in some ways ironic that an industry which was once known for its high financial rewards to those who were willing to take high risks resulting in high returns (albeit with little or no accountability) is now turning into one where individuals (not just firms) will be accountable and potentially punished for any mistakes and for badly managed risk.

This paradigm shift in the industry highlights that it is absolutely essential that senior managers have the ability to easily demonstrate the steps and full audit trails relating to regulatory risks and issues at any point in time. SMR may be a UK regime, but individual accountability of senior managers in the industry is almost certainly a global phenomenon. Under these circumstances, senior managers within financial services firms in the UK and worldwide need to be equipped with adequate regulatory management tools.

If this can be achieved, then the crown can sit a little more comfortably on the heads of those who have been nominated to wear it.

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The Future of Finance Teams: Digitally Transformed

The Future of Finance Teams: Digitally Transformed 1

By Simon Bull, Sales Operations & Business Development Manager at Aqilla

Finance teams haven’t always been at the forefront of digital transformation trends, not least because their heavily regulated environment can – to an extent – create understandable caution and slow the pace of technology change. For instance, finance teams will be familiar with storing their sensitive data on their office premises, keeping it under their own roof and control. As a result, software modernisation can get left behind thanks to an ‘if it ain’t broke, don’t fix it’ mentality that can inform the thinking of finance and IT professionals alike.

Yet, across the economy, the pressure created by lockdown to build more flexible and integrated tech strategies is rapidly growing, not least because of the need to work from home. In the case of many organisations, the transition to flexible, remote working was straightforward, albeit slightly turbulent, but the finance department may have found it more challenging to transition to the required standards of remote working.

In particular, digital transformation for finance teams increasingly means switching away from outdated in-house technology architectures and software products to flexible and more financially efficient cloud-based services. It’s an approach that offers a number of important potential advantages, and also some pitfalls to avoid:

  1. Cost Management: The cloud-based Software-as-a-Service (SaaS) approach that is the basis of many of today’s cloud computing businesses offers users the convenience of a monthly pay-as-you-go model. Instead of investing significant sums in one-off software purchases, for example, all users need to access cloud-based finance software services is a desktop computer, laptop or smart device and internet connectivity. In turn, this also saves money on the server hardware that has previously sat in the corner of the office, and it may no longer be needed at all. In selecting cloud-based finance software services, organisations should always compare pricing from several providers to make sure they are getting the most competitive deal.
  2. Stronger Security: The best cloud providers should have security at the top of their list of capabilities, and checking on their accreditations, policies and track record should always form part of any selection criteria. This should include areas such as data protection, backup services and their ability to deal with common security issues, such as ransomware.
  3. Service as Standard: ‘Service’ is a buzzword employed by many SaaS providers, but it’s something that shouldn’t be taken for granted. Done well, cloud-based customer support and service can deliver an outstanding experience where the provider really feels like an extension of the in-house IT Team. The best ways to assess the service capabilities of any cloud provider are to ask for references from existing customers, check online reviews and evaluate their Service Level Agreement (SLA) to understand the small print of any agreement.
  4. Built for purpose: one of the major plus points of adopting a cloud-based software service is that they are built for purpose, and many offer an amazing degree of bespoke capabilities enabling every organisation to tailor them to their precise needs. This is in contrast to traditional software solutions that can, in effect, force the user to work in a prescribed way that might not be suited to their circumstances or priorities..

    Simon Bull

    Simon Bull

  5. Specialised Compliance: This is where the specialisation offered by many cloud software providers can be of particular benefit, and those serving the finance industry should have compliance at the heart of their product design. Even for the most niche requirements, there is often a software provider out there who is geared to meeting those needs.
  6. Better Performance: Today’s cloud-based finance software market offers a sophisticated range of options from simple entry-level functionality to powerful performance designed to fit the needs of even the biggest and most complex finance departments. Key features could include: extensive analysis, proper periodic management and business calendars, multi-currency, multilingual and multi-company operation, full VAT handling International coding, tax and language flexibility, automatic reconciliation / bank integration, built-in key performance measurement, advanced search, selection and drill-down, document and image scanning.

Without doubt, the future of finance will be one that is digitally transformed. Even before the pandemic, modernisation offered compelling arguments for change across the tech strategies of many finance teams. Lockdown has accelerated the pace of change because cloud-based finance software can help teams to adapt and capitalise on working from home to match the success digital transformation has brought to many other key business functions. To put it simply, Covid-19 has become a catalyst for a digital transformation in finance, particularly in moving finance and accounting software away from traditional on-premise solutions to built-for-cloud services.

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Trust matters more than ever in an uncertain world

Trust matters more than ever in an uncertain world 2

By Zac Cohen, COO, Trulioo

Trust in the time of COVID-19

Perhaps more than ever before, retail and investment banks the world over face a pivotal moment in their evolution, as banking transitions from a digital-first towards a digital-only landscape. The COVID-19 pandemic has put severe restrictions on traditional face-to-face or high street banking and forced sections of society that had previously been resistant to or unable to access digital banking to make the shift. This understandably brings with it significant anxiety and fear.

For an industry that has been striving to rebuild consumer confidence since the global financial crisis of 2008, COVID-19 presents a huge challenge. It needs to foster trust at a time when the world is facing unprecedented levels of uncertainty and stands on the brink of an even more severe global recession.

Without doubt, a thriving digital economy will be critical for the global economy to bounce back quickly and strongly from COVID-19. Therefore building online trust has become critical to our very future.

A billion reasons to protect customers

The global banking system processes more than a billion transactions every day, from transfers and domestic and international payments, to loan approvals and the creation of new accounts. And each one of these transactions represents an opportunity for some sort of financial crime, whether that’s money laundering, identity theft, bribery or the financing of terrorism.

The global pandemic has only served to accentuate this level of risk, with new threats emerging on the back of COVID-19, and bad actors looking to exploit new opportunities. In particular, online fraudsters are looking to target people who are using digital services for the first time as a result of the pandemic, often the most vulnerable groups in our society such as the elderly.

Research that we recently conducted in the UK and the U.S. found that concerns about online security are higher within financial services than in any other sector, with more than half of people (51%) reporting that they are ‘very concerned’ about identity theft when using financial services sites.

Crucially, 90% of people believe that banks have a responsibility to reduce cybercrime through whatever identity verification is necessary.

Building trust from day one

Of course, customers want online banking services to be responsive, intuitive and fast, but it’s important to recognise that, first and foremost, people want to know that their money and their personal data are safe.

Know Your Customer (KYC) and Anti-Money Laundering (AML) practices are now essential in enabling banks to not only identify each individual customer, but to build trust across the digital ecosystem more broadly.

Identity verification technology during the onboarding process enables a bank to demonstrate to its customers that it is taking their security seriously from the very outset of the relationship. First impressions count — more than three quarters (77%) of consumers claim that the account opening process can ‘make or break’ their relationship with a financial services brand.

Banks simply cannot afford anything other than optimal onboarding and identity verification – fail to deliver this and trust is immediately eroded and in many cases, the customer walks away.

On the other hand, where banks do succeed in demonstrating their commitment to security during these first engagements, delivering a fast, secure and seamless account creation process, they are able to develop a more meaningful relationship with their customers. As many as  84% of consumers report having greater trust in financial services brands that use real-time identity verification during the onboarding process and 71% are more likely to share more personal data.

A layered approach to identity verification

In order to provide first-class onboarding processes and establish trust at the outset of the customer journey, banks need to ensure they can deliver relevant and compliant identity checks for customers, dependent on their geography and the type of service or product that they are looking to access. They need to move beyond a ‘one size fits all approach’ to identity verification, which can lead to cumbersome or unnecessary checks on the one hand, and increased risk on the other.

This is why a digital identity network is so powerful. This is essentially a marketplace of hundreds of data sources, verification processes and tools that leverage network data intelligence to verify and authenticate identities online.

This marketplace approach lets businesses get a more holistic view of risk and then apply whichever verification layers are needed to provide assurance and build trust.

Zac Cohen

Zac Cohen

For example, a bank may only need to perform a basic KYC check when onboarding a customer with an established government ID number or driving license. If that same customer then wants to take out a loan, the bank would need to run other verification checks to create a higher level of assurance. And if the bank wants to onboard a customer whose only form of digital identity is a name tied to their mobile phone number, it would likewise build up assurance through multiple verification and authentication layers — for instance, ID document verification, which captures images from a person’s ID document and assesses its validity, combined with biometric authentication, which compares a selfie photo (taken and sent through the mobile phone) with the photo on an ID document.

With such a layered approach to identity verification, banks have complete flexibility and choice to apply the most appropriate identity checks at every stage of the customer journey, meaning that they can manage and optimise customer experience while minimising risk and ensuring compliance against a rapidly changing regulatory backdrop.

Building a global ecosystem of trust for the digital economy

To build and maintain online trust in such a complex and diverse environment is extremely challenging for banks.

Indeed, despite rapid digitisation across all sectors and regions, the internet continues to suffer from a lack of a critical identity layer that would solve many of these complex problems. While there are layers of protocols and methodologies for transporting data over networks, there is no protocol for transporting assurance. In online transactions, then, there is no standardized way to establish that an individual is who they say they are — the essence of identity.

Clearly this needs to change in order to drive trust, digital access and financial inclusion.

A digital identity network provides banks with the assurance they need in these turbulent times, protecting both themselves and their customers from fraud and delivering seamless customer experiences. In particular, it allows banks to enter new markets and reach new customers who have previously been marginalised or excluded from the digital economy, with confidence. In this way, digital identity can become a great equalizer, enabling more people to access and enjoy the benefits of a digital economy, built on trust.

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Workforce Diversity Matters To Our ESG Evaluation

Workforce Diversity Matters To Our ESG Evaluation 3

We believe the limited representation of Black voices in key decision-making processes prevents companies from reaping the benefits of a diverse workforce. It also exposes companies’ reputations to allegations of discrimination, as shown by recent calls on social media to boycott certain businesses after apparently racist behavior of employees were captured on video and shared. As such, we believe companies need to be deliberate in how they recruit, hire, and develop Black talent if they want to achieve a sustainable and diverse workforce, thereby improving ESG performance.

As part of our social assessment in the ESG Evaluation, we assess how effective a company is at developing a productive and inclusive workforce. Key indicators include employee retention and turnover rates, labor standards, pay, benefits, and rewards. We also assess whether fair labor standards are entrenched across the value chain. Moreover, we evaluate an entity’s preparedness to respond to long-term risks and opportunities, including from changing demographics and social patterns. We assess the extent to which decision-making demonstrates the company’s commitment to its long-term strategy and sustainability, as well as its success at building an inclusive workplace culture. These practices are particularly important given the presence of systemic racism, which continues to disadvantage Black people in corporate environments, particularly in the U.S.

U.S. workplaces have yet to achieve equal opportunity for people of different races, and policies have so far not fully addressed the widespread issue of racism. According to the Center of Public Integrity and the Washington Post, from 2010 to 2017, one million discrimination complaints were filed with the U.S. Equal Employment Office Commission. More than 30% of these cases related to racial discrimination.

Labour Market Outcomes Are Rooted In Systemic Racism

The Black community has long been subject to civil and human injustices that have contributed to a vicious cycle of low educational attainment, high unemployment, and concentrated poverty. This has made it difficult for Black people to enter the workforce, advance in higher wage work, and accumulate generational wealth. Poverty serves as a systemic hurdle to Black employees because it creates barriers to higher educational attainment, thereby limiting their ability to procure employment and financial opportunities that would enable wealth accumulation. In 2018, the Kaiser Family Foundation revealed that Black Americans have the second-highest poverty rate in the U.S. (after Native Americans, another highly marginalized group). The study also highlighted a striking wealth disparity; while the median net worth of a white household in 2016 was $103,000, for Black households it was only $9,200 (see chart 1).

Chart 1

Workforce Diversity Matters To Our ESG Evaluation 4

Yet, structural hurdles and enduring biases have also historically disadvantaged Black jobseekers, regardless of educational attainment. In the U.S., only 31% of Black employees are in management or professional positions, and a low proportion is in upper management positions (see chart 2).

Chart 2

Black Employees are largely underrepresented in management and professional occupations
Educational attainment of the labor force, age and above in the U.S.

Workforce Diversity Matters To Our ESG Evaluation 5

What’s more, Black employees are often held to higher standards than their white counterparts. A 2015 study by the National Bureau of Economic Research found that Black workers receive extra scrutiny in the workplace, leading to lower wages, slower promotions, and sometimes even job loss. This legacy may also create an additional barrier to career advancement, which is apparent in the low proportion of Black employees in upper management positions. Of the Fortune 500 companies, Black employees only account for 3.2% of executive and senior management and only 0.8% of CEOs (four in total) are Black (see chart 3).

Chart 3

Diversity And Inclusion Policies Are Only The First Step

Workforce Diversity Matters To Our ESG Evaluation 6

In our opinion, D&I programs are an important mechanism for improving racial equity in the workplace. They aim to link a company’s strategies, mission, and business practices in a way that supports demographic differences among talent and enables an environment in which all employees are empowered to contribute their unique views and perspectives. As D&I programs have evolved, they’ve begun to encompass initiatives such as targeted recruitment, diversity education and training, career development, mentoring, and grievance procedures. Done well, D&I programs offer several business benefits, from improved productivity to innovation, which help boost a company’s ESG performance by helping it anticipate changing consumer preferences and consumption patterns.

Several studies have investigated the link between diverse workforces and a firm’s financial performance. According to a 2020 McKinsey & Co study, companies in the top quartile for racial and ethnic diversity are 36% more likely to show financial returns that exceed the national industry median. Another study by sociologist Cedric Herring, during his time at the University of Illinois, Chicago, found that companies with the highest racial diversity were able to generate nearly 15x more sales revenue than firms with the lowest levels of racial diversity. Herring suggests that racial diversity is the most important predictor of a company’s competitive positioning, and a better indicator of sales revenue and customer attainment than a company’s size, years in business, and overall employee headcount. Diversity has also been linked to increased innovation potential. Studies show that diversity supports, enhanced creativity, more informed decision-making, increased capacity for innovation, improved customer acquisition, stronger revenue-generating potential, and better talent management.

Analyzing Diversity Remains A Challenge

Where available, we analyze a company’s ethnic diversity metrics as one indicator for a diverse workforce. Businesses tend to focus mainly on the workforce composition and on recruiting employees from different identity groups, including race, gender, age, culture, cognition, and education. Social equality activists are increasingly demanding that companies release diversity statistics, thereby holding them accountable for persisting race gaps.

Although transparency practices are improving, the availability of data is a persistent issue. According to the U.K.’s Business in the Community (BITC) Race at Work 2018 Scorecard report, only 11% of employers report ethnicity and pay data. In France, a race-neutral policy approach to education and employment stands in contrast to that in other European countries. It is illegal for employers or institutions in France to ask about someone’s race or ethnicity. The intent of this was to avoid discrimination. However, in 2006, more than 25 years after the 1978 law prohibiting the collection of ethnic data, a poll by research company TNS-Sofres showed that more than half of France’s black adults said they had experienced racial discrimination. Furthermore, companies more frequently report strictly on percentages of minority employees without commenting, directly or otherwise, on the positions they occupy. This can mask some disparities in terms of job level, promotions, or lack of diversity in certain roles.

We also take into consideration companies’ strategies to increase diversity including quotas, targets, or affirmative action policies. Over the past few years, several European countries have proposed or implemented diversity quotas for boards of companies, principally to increase female participation. The U.S. state of California followed suit in 2018, while legislation is pending in other states. Although still controversial, quotas have helped increase the number of women on boards. Similar policies on ethnic diversity are largely missing. In the U.K., the 2017 Parker Review set a voluntary target for FTSE100 boards to have at least one director from an ethnic minority group by 2021. The Review’s 2020 update shows some progress but not full compliance with the recommendations.

Regardless of the approach a company takes to increase workforce diversity, it is clear that quality data is a necessary ingredient of an effective diversity strategy. As such, we believe transparency at all levels of the organization is imperative for companies to solidify the trust and loyalty of their employees, suppliers, and shareholders. In turn, this will help boost productivity and strengthen the potential for innovation, thereby supporting ESG performance.

The Emphasis Must Be On Inclusion

Recruiting ethnic minorities does not necessarily translate into an environment that’s free of discrimination, allowing each employee an equal opportunity to advance. In our opinion, employers with a culture that tolerates discriminatory practices and microaggression are vulnerable to productivity lapses, decreased innovation, and lower creativity. Therefore, we believe the success of D&I initiatives appears to hinge on the inclusion side of the equation, which should ensure employees feel their contributions are appreciated and full participation is encouraged. According to author and inclusion strategist Verna Myers, Vice President of Inclusion Strategy at

Netflix, “Diversity is about being invited to the party. Inclusion is about being asked to dance.” Analyzing inclusion practices could provide better insight into how companies manage more covert forms of discrimination associated with microaggression. In a U.S. national survey of over 3,700 office workers conducted by the National Opinion Research Center (NORC), 58% of black respondents said they have encountered racism at the workplace. According to the NORC, workplace prejudice often shows up in subtle ways, through microaggression, typically during employee interactions through comments that proliferate Black stereotypes. Examples include referring to Black employees as intimidating, or unprofessional because of their hairstyles, thus creating a situation in which these employees are perceived as “not right” for the job. Such a toxic environment can go undetected by senior management, particularly when people of color are underrepresented at the workplace and in management positions. Many instances of discrimination also likely go unreported, making it even more difficult to expose covert forms of racism in corporate culture. In some cases, microaggression could ultimately result in higher staff turnover rates, one of the factors that informs a company’s Social Profile in our ESG Evaluation.

Many corporate leaders have committed additional resources to D&I programs in the wake of the Black Lives Matter protests. However, the success of these programs lies in how they resonate with employees. Literature on this topic suggests that achieving true inclusion requires a shift in the organizational culture to acknowledge the value of different backgrounds, expose conscious and unconscious biases, and create an atmosphere of respect and empathy. Managers, in particular, play a crucial role in employee development and are therefore important stakeholders in supporting racial inclusion. However, many are not necessarily inclined to reflect on or talk about racial discrimination, and without a business culture that fosters inclusion, meaningful change is unlikely to result.

Companies have started promoting conversations with Black employees to better understand their experiences, which we believe is a starting point. Ultimately, achieving a sustainable diverse workforce and addressing system racism will require continued leadership and accountability. A 2018 Boston Consulting Group study of more than 1,700 companies in eight countries, across different industries and sizes, found that five key factors help diversity to flourish:

  • Participative leadership: managers support employee contributions;
  • Strategic priority: top management and the CEO clearly demonstrate support for diversity; – Frequent communication: free and open communication is encouraged within teams;
  • Culture of openness to new ideas: employees feel that they can express their perspectives without fear of retaliation; and
  • Fair employment practices: employees with equal roles achieve equal pay, and companies enact robust anti-discrimination policies.

Looking To The Future

The Black Lives Matter movement has ignited a broader awareness of racism in society that has put the corporate sector in the spotlight. We believe companies’ diversity track records will be increasingly scrutinized, making a diverse and inclusive workforce a reputational imperative. In our view, more corporate entities will treat the challenge of workplace diversity as they would any other existential risk, and therefore gather the right information, including opting into voluntary diversity initiatives, to make the most informed choices.

A Call To Action: The Race At Work Charter

In collaboration with the U.K. government, the BITC established the 2018 Race at Work Charter detailing five actions all employers, regardless of sector, could undertake to further support diversity and inclusion. Since the Charter’s inception, more than 100 companies have added their signatures, including the National Grid, Goldman Sachs, and Deutsche Bank. By joining this initiative, companies are committing to taking meaningful action against discrimination in the workplace. The five actions are to:

  • Appoint an executive sponsor for race.
  • Report ethnicity data metrics and monitor progress.
  • Commit, at the Board level, to zero tolerance of harassment and bullying.
  • Clearly state that promoting equality in the workplace is the responsibility of all managers.
  • Take meaningful action to support the career progression of ethnic minorities.

The success of a company’s D&I efforts will be reflected in several indicators, including: the proportion of Black employees in the workforce overall, also in management and leadership positions; and the pay gap between employees in similar roles. Large, technologically advanced companies will likely be among the first to back their D&I commitments with meaningful targets and report regularly on progress. In the end, an effective, inclusive framework that supports long-lasting diversity and ESG goals depends on sound communication and ongoing commitment of employees at all levels of the organization.

Related Research

  • Environmental, Social, And Governance: Why Corporations’ Responses To George Floyd Protests Matter, July 23, 2020
  • The ESG Pulse: Social Factors Could Drive More Rating Actions As Health And Inequality Remain In Focus, July 16, 2020
  • Environmental, Social, And Governance Evaluation Analytical Approach, June 17, 2020
  • Environmental, Social, And Governance: How We Apply Our ESG Evaluation Analytical Approach: Part 2, June 17, 2020
  • How We Apply Our ESG Evaluation Analytical Approach: Part 2, June 17, 2020
  • People Power: COVID-19 Will Redefine Workforce Dynamics In The Post-Pandemic Era, June 4, 2020
  • The ESG Lens on COVID-19, Part 2: How Companies Deal with Disruption, April 28, 2020
  • COVID 19: A Test Of The Stakeholder Approach, April 21, 2020
  • The ESG Lens On COVID-19, Part 1, April 20, 2020
  • How To Navigate The ESG Risk Atlas, April 11, 2019
  • How We Apply Our ESG Evaluation Analytical Approach, April 10, 2019
  • The ESG Advantage: Exploring Links To Corporate Financial Performance, April 8, 2019

External Research

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