IFoA SP9 study materials
IFoA SP9 study resources

IFoA SP9: Risk culture, conduct and behavioural aspects of risk

IFoA SP9 · Work through your exam, one topic at a time.

All guide sections

Risk culture, conduct and behavioural aspects of risk

What the exam tests

Culture, conduct and behaviour: how incentives, leadership and group dynamics shape risk outcomes, and how to assess and change culture.

Core rules

  • Tone at the top is necessary but not sufficient; middle management and incentive design drive behaviour.
  • Conduct risk arises from how the firm and staff behave towards customers and markets; it is not confined to compliance breaches.
  • Behavioural biases: overconfidence, confirmation bias, anchoring, availability, groupthink, herding and loss aversion distort risk decisions.
  • Culture indicators include speak-up data, whistleblowing volumes, policy breaches, remuneration structures, attrition, near-miss reporting and audit findings.
  • Culture assessment should triangulate surveys, interviews, data and observed decisions.

Worked example

A sales team meets targets by selling complex products to retail customers. Complaints rise. The firm responds with a training module. Reasoning: the root cause is likely the incentive scheme and product governance, not knowledge. Training leaves the reward for mis-selling intact. Better: redesign incentives with quality and suitability measures, strengthen product approval, monitor complaints and vulnerability data, and protect whistleblowers.

Traps

Treating culture as an annual survey score; blaming individuals for system failures; ignoring remuneration; assuming conduct risk belongs only to compliance; recommending 'tone from the top' without mechanisms.