Our Conduct Regulation Assurance team plays a key role in ensuring NFU Mutual meets its regulatory obligations, while continuing to deliver high quality customer service. Their devolved approach to this important work gives them a lot more scope to make a difference to both business and customers. We spoke to some of the team to find out how this approach works and what they enjoy about it.
Can you explain how your devolved approach works?
Kamlesh Parbat, a Conduct Regulation Assurance Specialist in the team, starts by explaining the FCA’s three lines of defence model for financial services companies. “Most financial institutions will have a three lines of defence model,” he says. “The first line of defence is the front-line staff who support customers. The second line of defence is typically your compliance function, like our team. And the third line of defence is the internal audit team.”
NFU Mutual has those three lines of defence, says Paul Richards, another Assurance Specialist, but responsibilities are structured differently to other organisations he has worked in. “Here, the first line – our front-line functions – have ultimate responsibility for complying with the regulations and making sure we deliver good customer outcomes,” he explains. “They’re supported by Compliance Consultants, who act as business partners to a specific business area. So, they offer technical compliance advice and interpretation of the regulatory handbooks to enable those first line functions to fulfil their responsibilities. Then our team comes in as a slightly more independent function to test whether what they’re doing is hitting the mark. So, we’ll look at whether their controls are appropriately designed and if they’re working effectively.”
How does that differ from other organisations?
Paul has worked in other organisations and says this is a different approach to what he’s experienced. “In some other companies, you have a compliance department who sets a policy and goes out and makes sure that people in the business adhere to that policy, so it’s top-down and quite directive.”
He says the devolved model at NFU Mutual isn’t as prescriptive and encourages everyone to take ownership of delivering good customer outcomes. “Compliance gives the business a very clear steer on their compliance responsibilities and regulatory expectations. Then, with the support of their Compliance Consultant, the business will consider the best way of achieving those expectations. It’s a collaborative approach. Our team adds value because we can take a step back, look at what the business teams have designed, see whether it looks reasonable and then test it.”
Kamlesh agrees about it being more collaborative. “I don’t want to sound clichéd, but we’re almost like one big family at NFU Mutual. We’re all trying to achieve the same goal, which is delivering good outcomes and a good experience for our end customers. In our reviews, it’s about how we can work together to achieve this goal, and how we can support the business to mitigate any risks and meet regulatory requirements.”
Christian Stewart, a Compliance Team Leader, says that, for him, this makes his work far more interesting. “The first line knows their area, so they’re responsible for designing the controls because they know what will work best from a commercial perspective. That makes it more varied for us as the second line function, because we’ve got this whole host of things that they’re designing and we’re assessing,” he says. “We can get into the detail a bit more and make more judgement calls. It’s very different to having a set policy, which could involve more of a tick-box exercise.”
How much of a difference do you think being a mutual makes?
Paul says the team’s approach is all part of the NFU Mutual way of doing things. “I’d say that culturally, we’re always looking to do the right thing for our customers and our people,” he explains. “When you talk to people in the business, we always focus on whether something’s good for the members, or good for our people. Our success as a company is based on delivering products and services that our customers value.” And he says this is why the number one priority for the team is to gauge if something delivers a good customer outcome. “That’s our role really, to make sure that the propositions work, and that we meet customer needs.”
For Raluca Boroianu-Omura, the Head of Conduct Regulation Assurance, this is one of the main differentiators. “We have full alignment with the interests of our customers,” she says. “And that comes from being a mutual.” How is that reflected in the team culture? For Kate Brain, an Analyst in the team, collaboration and customer focus are at the heart of the team’s approach. “I have complete trust in my colleagues. They’re supporting the business, but supporting me and each other, too,” she says. “So, you can have those open conversations and challenge each other where necessary, because you value each other’s opinions.” And she adds: “It’s about having the same behaviours across the team. We’re all here to do right by the business, our members and each other. We all want to do a good job.”
Raluca admits she enjoys being challenged by her team. “There’s a nice collegiate way that people challenge each other. And it’s an incredibly supportive environment. You can bring your whole self to work.”
Christian agrees, saying that this support is what makes working in the team so enjoyable for him. “We don’t work in a silo – we do genuinely work together and if people are struggling and need support, we help them.”
Paul says this comes down to the shared values among the team and the wider business: “I think the whole team has such a strong shared value that we want the customers to get a good service,” he explains. “You get the feeling that you can make a difference, so when you spot something that could be better, you speak out. And I think that’s present in other NFU Mutual teams, too.”
For Christian, this is what makes their work so fascinating. “We’re trying to get to good customer outcomes as a company, but there are thousands of different ways to achieve that. That’s what I find interesting – looking at which methods are the best and how as a company we can tweak the things that work. There are always judgement calls to be made because there are a thousand different ways of achieving our goal.”