Bridging the gap: Understanding behavioral risk in organizational culture

Vera Cherepanova (, is the CEO and Founding Partner of Studio Etica, Ethics Advisor, Speaker, and Compliance Author in Milan, Italy.

In today’s landscape, the spotlight on integrity and ethical culture within organizations is relentless. Wrongdoing and adverse outcomes are often rooted in behavioral issues, pointing to deeper cultural concerns.

There is an increasing trend from regulators worldwide to expect businesses to manage organizational culture. Although regulation has a limited role in mandating a certain culture, it does serve as a potent catalyst for cultural improvement, drawing organizations’ attention to and expectations regarding culture and conduct.

Regulatory bodies such as the U.K.’s Financial Conduct Authority[1] and De Nederlandsche Bank in the Netherlands[2] have emphasized the necessity for cultural change within the financial services industry. The U.S. Department of Justice’s Evaluation of Corporate Compliance Programs guidelines address how an organization measures its culture of compliance and which steps it takes in response to the measurement.[3] Moreover, financial authorities require internal auditors to evaluate and comment on behaviors and culture in countries like the U.K., Singapore, and Australia.

Regardless of your industry, addressing ethics and organizational culture is a fundamental requirement for an effective ethics and compliance program.

But here’s the crux: how can organizations move beyond superficial culture assessments and generic employee surveys to harness advanced techniques for measuring and improving their cultures?

The answer lies at the intersection of effective ethics and compliance programs and enhanced risk management, where organizations shift their focus toward understanding behavioral risk.

This article offers a framework to set up a behavioral risk assessment capability, including identifying areas prone to behavioral risks, carrying out subculture audits, and developing an organization’s behavioral anchors. These steps provide a strong foundation for sustainable cultural change.

This document is only available to subscribers. Please log in or purchase access.

Would you like to read this entire article?

If you already subscribe to this publication, just log in. If not, let us send you an email with a link that will allow you to read the entire article for free. Just complete the following form.

* required field