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Principle 13: Culture

Managing agents should be inclusive, creating a diverse high-performance culture.

In order to support this, managing agents should:

Demonstrate leadership focus on fostering an inclusive, high-performance culture

Ensure behaviour expectations are clear and there is zero tolerance for inappropriate behaviour

​Encourage speaking up, ensuring there are appropriate tools for employees to do so, and the tone is set from the top​

Ensure diverse representation within their workforce and their leadership population. Be inclusive in how they hire and retain talent and ensure they reflect society and their customers

Understand their employee population, collect appropriate data and take action to create an inclusive employee experience

Below are some of the frequently asked questions about this Principle, including the questions that were asked in the Technical Briefing session(s).

If you have any further questions, please reach out to

We won’t distinguish based on each firms’ size. Initially all firms will be considered equally. The comparison provided in the Culture Survey is for the overall market. Looking at the last Culture Survey results, there was not a correlation between organisation size and culture survey results, nor between workforce composition / diversity and organisation size. We will however monitor this and consider whether any differentiation makes sense in future.

The Culture Survey in 2022 is very similar to the previous survey so that we can see progress and provide comparisons. Going forward, we will review the Culture Survey, with a view to making it more focused and simple.

We will be looking at diversity data more broadly, collecting and sharing the picture across the market for more characteristics such as LGBT+ and Disability, and in the Culture Survey we have included socio-economic background as a demographic this time. At this stage, we don’t have plans to set more representation targets.

Following the issues raised by Bloomberg, the focus of the culture, diversity and inclusion work was around gender, and a 35% women in leadership short term target was set. Since then we introduced the 1 in 3 hiring ambition to increase ethnic diversity in the market. This was to drive tangible action to broaden the talent pool we were attracting to the market. On social mobility, this is a growing area of activity - in the Corporation we have been focused on this. We are starting with collecting some data through the culture survey on social mobility, which will be an input to how we move forward.

We will advise each firm what the threshold of responses are in order to receive culture survey results. Assuming that is met, we will set up a call to talk through the culture survey results, to support you interpreting the data.

We’re trying to shift that mindset – one of the reasons we wanted to build out a culture principle is to make sure culture is taken into account

We should be able to make those brave decisions through our CPG process

It’s not just about what you tell us, it’s about what we’re observing too and those open conversations. 

It’s taking a rounded look at what’s going on in a firm. We hope that this encourages a more grown-up conversation with you as we are all trying to move towards a better culture in the market, rather than firms thinking they should be less transparent.

Part of the data collection asks what proportion of your workforce chooses not to share their data and where there is no data. 

Therefore, we still get a rounded view on your firm

If you have none you may be in the early stages of building trust and transparency so we would have a conversation about how you are building this within your organization. If there is a high proportion that this applies to, we will have a conversation with you on how’s best to collect this diversity data.