The senior managers and certification regime in financial firms: an organisational culture analysis

ABSTRACT This article critically interrogates the experience of the implementation and enforcement of the Senior Managers and Certification Regime (SMCR) in light of interdisciplinary literature on organisational culture. We demonstrate that the SMCR brings the promise of enhancing effective regulatory supervision of firm culture, supporting the incipient professionalisation of senior manager functions in the financial sector and discerning tangible aspects of artefacts and behaviours that constitute the external layer of good culture. However, we argue that, apart from the more obvious risk of too little enforcement or enforcement targeted at misconduct in the private sphere, there is a risk that a perception of rigidity in enforcement may lead to the development of a counterproductive culture, especially if firms unduly rely upon tick-box quantitative measurement approaches to culture management, and that sound culture may be simplistically equated to compliance with the SMCR. This necessitates a careful and nuanced approach to supervision.