Why Culture Change Can Feel Like a Personal Attack
And Why Regulation Can’t Fix That
Representing senior individuals in claims involving major City institutions, including NatWest, Barclays, Deutsche Bank and UBS, provides a perspective not always reflected in policy papers and annual reports. From that perspective, one thing is clear: sexism, harassment and discrimination remain deeply embedded workplace issues. Despite years of scrutiny and reform, meaningful change continues to lag behind rhetoric.
Resistance to culture change at senior leadership level is rarely ideological. It is psychological. When reform challenges behaviours that once conferred status, authority and success, it is often experienced as a personal attack. Regulation can curb behaviour, but it cannot resolve this deeper identity conflict, which is why compliance so often fails to deliver genuine cultural change.
Leadership identity
Recent regulatory reform has sharpened expectations around workplace conduct, accountability and psychological safety. Yet persistent evidence of toxic culture across regulated sectors demonstrates a consistent truth: compliance alone does not change culture.
For many senior leaders, calls for cultural reform are not always experienced as forward-looking improvement, but as retrospective judgement. Language around toxicity, misconduct and inequality can feel like an implicit critique of the systems through which they achieved authority and success. Reform is therefore heard less as “this must change” and more as “you were the problem”.
That distinction matters. Where leaders experience reform as a challenge to legitimacy rather than a governance requirement, predictable defensive responses follow: minimisation of harm, nostalgia for earlier norms, or claims that current standards are excessive. These reactions do not always reflect bad faith, but they do reflect identity protection, a powerful barrier to meaningful change.
Boards should be alert to this dynamic. Resistance at the top is often subtle, rationalised and professionally articulated, making it far harder to confront than overt misconduct elsewhere in the organisation.
The cost of looking back
Effective cultural reform requires leaders to confront uncomfortable questions about past behaviour, tolerated norms and the consequences of silence. This is not simply a technical exercise; it carries emotional and reputational weight. Senior leaders are being asked to hold two truths at once: that they may have acted lawfully and successfully within prevailing norms, but that those norms caused harm.
Why regulation stops short of culture
Regulation remains essential. It establishes minimum standards, protects whistleblowers and creates consequences for the most serious failures. But regulation cannot address belief systems, informal power structures or identity threat. As a result, many organisations learn to comply without committing. Policies are updated, training delivered and reporting lines formalised, while informal norms remain intact. Behaviour improves where scrutiny is highest, but cultural patterns persist beneath the surface.
Compliance activity can create a false sense of assurance, masking underlying cultural fragility until issues surface through litigation, regulatory intervention or public exposure. Where leadership identity remains unexamined, compliance also becomes a defensive exercise. Focus shifts towards managing legal exposure, reputational risk and regulator relationships, rather than understanding lived experience within the organisation. This approach may satisfy short-term governance requirements, but it erodes trust internally. Employees recognise the gap between stated values and tolerated behaviour. Over time, silence becomes rational, reporting declines and problems surface only once they are severe and costly.
Boards should therefore be cautious of culture metrics that rely solely on aggregated data or the absence of complaints. In many cases, these indicators reflect under-reporting rather than improvement.
How to shift mindsets
If cultural change at senior level is to be meaningful, boards must move beyond awareness and into structural intervention. Mindsets do not shift because leaders are persuaded; they shift when the conditions under which leadership operates are altered.
The starting point is clarity. Boards must define what acceptable leadership behaviour looks like in practice, not just in policy. Ambiguity at the top is quickly replicated below. Where expectations are selectively enforced or softened for high performers, cultural reform will fail.
Accountability must then be made personal. Culture cannot remain an abstract organisational concept; it must be experienced by senior leaders as part of their own performance assessment. This requires embedding behavioural expectations into appraisal, remuneration and succession decisions, and ensuring that culture metrics carry real weight alongside financial outcomes. Where commercial success consistently outweighs conduct, stated values will lose credibility.
Boards must also ensure that leaders are exposed to unfiltered evidence of impact. Aggregated surveys and headline dashboards rarely change behaviour. Meaningful engagement comes from qualitative data: lived experience, whistleblowing insight, exit feedback and case studies presented in a way that cannot be delegated or explained away. The objective is not blame, but consequence.
Crucially, challenge must be normalised at the top. Boards should examine whether senior forums genuinely permit dissent, or whether challenge is subtly penalised in the name of collegiality. Chairs and independent non-executive directors play a critical role in disrupting group think and ensuring that difficult conversations are not deferred or softened.
Finally, boards must be prepared for leadership turnover. Not all leaders will be willing or able to adapt. Cultural change at senior level often involves difficult decisions about role, progression or exit. While uncomfortable, this is sometimes the clearest signal that reform is real. Retaining leaders whose behaviour contradicts stated values undermines every other intervention.
Governance must go further
Lasting cultural change requires boards and senior leaders to move decisively beyond compliance and into ownership. Accountability must be visible, consistent and meaningful, including at the highest levels. Historical success cannot confer immunity from scrutiny.
Culture cannot be delegated. It cannot be resolved through policy alone, nor outsourced to HR or compliance functions. It is a governance issue that demands sustained attention, challenge and leadership from the top.
The organisations that make progress are not those with the most comprehensive rulebooks, but those whose leaders are willing to separate personal identity from institutional reform and to accept that authority carries responsibility not only for outcomes, but for the culture in which those outcomes are achieved.
If you would like to discuss any of the issues raised in this article, please get in touch.
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