Culture Audits
Culture is the backbone of regulatory compliance. The FCA has made it clear that firms are judged not only on their frameworks, policies, systems & controls, but on the culture that underpins decision-making and outcomes.
At Chameleon Compliance, we specialise in Culture Audits that go beyond a tick-box exercise. We help you uncover the true drivers of behaviour in your business and assess how well these align to the FCA’s Four Drivers of Culture:
- Leadership
- Purpose
- Governance
- Reward & People Policies
Our approach ensures that culture isn’t just something written into policies, but something lived by your people every day.
Why Culture Audits Matter
Regulators increasingly expect boards and senior managers to evidence that their firm’s culture supports good outcomes, integrity and sound governance.
A strong, proactive culture can protect your firm from conduct risks, regulatory breaches and reputational harm.
Weak culture is often at the root of failings highlighted in FCA enforcement cases, from poor treatment of vulnerable customers to misaligned employee incentives.
A Culture Audit gives your board, senior managers and stakeholders clear visibility of what’s working well and where improvements are needed. If you’re a senior manager, visit out centre of excellence, The Culture Space to learn more about how culture is fundamental to success in the SMF role.
What Our Culture Audits Cover
We tailor each audit to your firm’s context and priorities. Areas of focus typically include:
- Board and Executive Behaviours – how leadership sets the tone from the top.
- Decision-Making – clarity of accountability, escalation routes and understanding how decisions are made.
- Governance Structures – whether the board, sub-committees, reporting lines and oversight are effective in practice.
- People and Incentives – alignment of HR policies, rewards and recognition with regulatory expectations.
- Purpose and Values – how well your stated purpose translates into day-to-day behaviours and outcomes.
- Risk Culture – conduct, openness in speaking up, handling of conflicts of interest and psychological safety across the organisation.
- Customer Outcomes – evidence that good outcomes are at the heart of the business model, product and service design.
How We Work With You
We know that every firm is different. Some need an independent light-touch review to validate their existing culture initiatives, whereas others require a deeper dive to address concerns or to prepare for regulatory scrutiny.
Our process is collaborative and proportionate. We combine:
- Document and policy reviews this is the formal side of governance.
- Interviews and workshops with employees at all levels.
- Observation of governance meetings such as Board and sub-committee meetings.
- Benchmarking and insights from across the sector.
This approach ensures we don’t just measure what’s written down, but also what happens in reality.
The Outcome
At the end of a Culture Audit, you’ll receive:
- A clear, independent assessment of your firm’s cultural strengths and areas for improvement.
- Practical recommendations that go beyond compliance to help you build resilience and sustainability.
- Insight into how your culture stacks up against regulatory expectations and sector best practice.
- Assurance for your board and senior managers that they can evidence a focus on culture and demonstrate ‘reasonable steps’ under the SMCR.
Who Benefits from a Culture Audit?
A Culture Audit is particularly valuable for:
- Boards and chairs seeking assurance on culture and governance.
- Senior managers (SMFs) under the SMCR who need to evidence reasonable steps.
- Compliance Officers and heads of risk, embedding cultural metrics into monitoring.
- HR leaders aligning people practices to regulatory expectations.
- Internal audit teams, looking for independent insight.
- Firms preparing for an FCA visit or thematic review.
Why Choose Us
We don’t believe in generic, one-size-fits-all culture assessments. Our role is to act as an independent expert, giving you only what you need and nothing more. Whether it’s a short project or ongoing support, we’ll work with you to:
- Provide peace of mind that culture is being assessed objectively.
- Support your leadership team’s accountability under the SMCR.
- Help you to demonstrate to regulators that culture and conduct are taken seriously.