A global guide to senior management accountability
This guide to senior management accountability will consider the steps being taken by national
regulators across the globe to improve organisational culture
and governance through enhancing the accountability of senior
management. We look at the common key features of the
various national regimes and highlight some of the difficulties encountered by
firms in seeking to respond to and implement these changes.
Finally, we will assess whether increased senior management
accountability is likely to be an effective medium for delivering the
widespread changes to organisational culture required to restore
trust and confidence in the financial services sector.
In the aftermath of the 2008 financial crisis, the
role played by senior managers in driving desirable conduct
outcomes in firms has been at the forefront of the international
regulatory agenda. Whilst initial focus fell upon rebuilding the
balance sheets and financial resilience of shattered institutions,
there was a shared recognition that good governance and
culture would play an equally important role in any recovery.
Individuals, especially senior individuals, play a crucial role in
fostering good governance. Organisational culture is, ultimately,
an outworking of the values and influence of those who lead
an organisation. It is reflected in every decision at every level,
from future strategic direction to who in a front-line team gets
promoted ahead of their, possibly equally capable, colleagues.
It is much more than simply the ‘tone from the top’ and yet, it
cannot change without significant leadership and action from
The financial crisis exposed the difficulties that firms managed
largely along functional lines faced in articulating who was
responsible for specific business areas within a legal entity
model of governance that is still largely prevalent. Leadership
was exposed as considerably less effective than required.
This has resulted in many national regulators reforming their
frameworks for regulating the key individuals and strengthening
accountability within local firms.
The full report
Explore the approaches taken by national regulators using the map below, or if you are a Linklaters client, log in or subscribe to our Client Knowledge Portal to access the full guide.