On 14 Could 2026, Barcelona hosted Cumplen ONE DAY COMPLIANCE, one in all Spain’s most important annual gatherings for compliance and ethics professionals. Towards a backdrop of accelerating regulatory change throughout Europe, practitioners convened to look at not solely what their packages require on paper, however what they’re truly producing in observe. The query that ran by means of a lot of the day was deceptively easy: how do we all know our tradition is working?
That query has moved from the margins of compliance discourse to its heart. Regulators, prosecutors, and boards are not happy with the existence of insurance policies. They need proof of affect. And because the hole between acknowledged values and lived organizational conduct turns into more and more seen – and more and more consequential – the strain on compliance officers to measure, not merely describe, moral tradition has by no means been higher.
Guillem Casòliva Cabana, Senior Compliance and Ethics Advisor at LRN, addressed that strain instantly in his roundtable on the occasion. Drawing on LRN’s Moral Tradition Benchmark Report, which surveys 1000’s of staff throughout industries and geographies on the behavioral realities of organizational tradition, Casòliva laid out a transparent argument: moral tradition just isn’t a values assertion. It’s the behavioral working system of an organization. And like every working system, it may be understood, recognized, and improved, however provided that organizations are keen to take a look at what is definitely operating beneath the floor.
Perception 1: Moral tradition drives conduct and you can not enhance what you haven’t outlined
“Earlier than you may measure your tradition, it’s important to resolve what you’re truly measuring. That sounds apparent. It hardly ever is.”
The primary argument Casòliva pressed upon the room was definitional. Many organizations discuss moral tradition fluently – in annual stories, in onboarding supplies, on the town halls – with out ever having specified what they imply by it. Tradition turns into a synonym for values, or for tone-from-the-top, or for the absence of scandal. None of these definitions is operational. None of them offers a compliance staff something to measure.
The framing Casòliva supplied was extra exact: moral tradition is the set of behavioral norms, expectations, and alerts that truly govern how folks make selections when nobody is watching. It consists of what will get rewarded, what will get tolerated, what will get ignored, and what will get punished. It’s the lived expertise of working inside a company, not the supposed expertise. And it drives conduct, good and unhealthy, extra reliably than any coverage doc.
The sensible implication of this framing is critical. If tradition is a behavioral driver, then the compliance perform just isn’t merely answerable for guidelines. It’s answerable for understanding and shaping the atmosphere by which guidelines are both adopted or quietly put aside. That duty can’t be discharged (to HR) and not using a clear definition of what the goal seems like. Definition and measurement aren’t separate actions. They’re the identical argument made in sequence.
Perception 2: Regulators are shifting from effort to effectiveness, and moral tradition is the brand new proxy
“The query is not whether or not you’ve a compliance program. The query is whether or not your compliance program has modified how folks behave.”
The regulatory atmosphere in Spain and throughout Europe has shifted in ways in which make the measurement of moral tradition not merely advisable however, in a number of respects, legally materials. The operative phrase in Spanish prison legal responsibility doctrine, launched by means of Article 31bis of the Legal Code by Constitutional Legislation 1/2015, is effectiveness. An organization looking for to cut back or get rid of prison legal responsibility should reveal not {that a} compliance program exists, however that it truly features. Round 1/2016 of the Fiscalía Basic del Estado strengthened this course: prosecutors deal with proof of real moral dedication, together with inside investigations and culture-building efforts, as mitigating components in prison proceedings. That commonplace just isn’t met by a coverage library.
Spain’s Whistleblower Safety Legislation (Legislation 2/2023), which entered into power in March 2023 and transposes EU Directive 2019/1937, prolonged this logic additional. All organizations with fifty or extra staff at the moment are required to implement inside reporting channels and lively ethics and compliance danger administration. The regulation is specific about its goal: selling a tradition of ethics and regulatory compliance. Non-compliance carries fines of as much as a million euros. The CNMV’s Good Governance Code 2020 likewise established ethics codes and whistleblowing channels as governance requirements for listed corporations, and the forthcoming 2026 revision, presently in skilled committee, explicitly frames selling a real company moral tradition that permeates all ranges of the group, from the board downward, as a brand new governance expectation.
Perception 3: Moral tradition will be measured empirically
“You aren’t measuring what folks say they consider. You’re measuring what the atmosphere round them alerts is definitely acceptable.”
Some of the persistent obstacles to tradition evaluation is the belief that tradition is simply too intangible to quantify. Casòliva Cabana challenged that assumption instantly. Moral tradition will be measured – empirically, rigorously, and in ways in which produce actionable knowledge – by means of a mix of structured surveys, qualitative insights, and behavioral knowledge evaluation. The LRN Moral Tradition Benchmark Report is constructed on exactly this technique, aggregating responses throughout 1000’s of staff to trace not values within the summary however the behavioral alerts that form day-to-day decision-making: whether or not folks really feel protected elevating considerations, whether or not they consider misconduct is addressed, whether or not their supervisor fashions the conduct the group claims to anticipate.
Surveys, when designed effectively, seize notion at scale. They floor the hole between what management believes is going on and what staff are literally experiencing. Qualitative strategies like focus teams, structured interviews, open-ended questions, add texture and specificity, revealing the reasoning behind patterns that survey knowledge surfaces however can not absolutely clarify. Behavioral knowledge, together with using reporting channels, the character of points raised, and the way these points are resolved, offers a 3rd layer of proof grounded in what folks truly do somewhat than what they are saying.
The purpose Casòliva made is that measurement just isn’t non-compulsory. It’s the mechanism by which organizations transfer from assumption to proof. The choice, working on the idea that tradition is wholesome as a result of no disaster has occurred, just isn’t a compliance posture. It’s the absence of 1. The organizations that seem in enforcement actions hardly ever believed, within the interval earlier than these actions, that their tradition was an issue. Measurement exists exactly to floor what assumption obscures.
Perception 4: Subcultures reveal what compliance packages should truly deal with
“Your values assertion applies to the entire group. Your tradition doesn’t. Each staff resides a barely totally different model of it.”
Some of the virtually necessary outputs of moral tradition measurement is the invention of subcultures. No giant group has a single, uniform tradition. It has a acknowledged tradition – the values, behaviors, and expectations articulated on the company degree – and it has a set of lived cultures that fluctuate by staff, perform, geography, and management. These subcultures aren’t aberrations. They’re the norm. And they’re the extent at which compliance conduct is definitely formed.
Casoliva reveals in his PhD thesis significant cultural divergence between items throughout the identical group. A industrial perform below intense gross sales strain might develop norms round reducing corners which can be invisible to the authorized staff three flooring away. A subsidiary working in a distinct regulatory atmosphere might have internalized totally different requirements of what constitutes acceptable conduct. A staff whose supervisor fashions openness and accountability will behave otherwise from one whose supervisor alerts, by means of inaction, that elevating considerations just isn’t well worth the effort. These variations don’t seem in a tradition assertion. They seem in measurement.
The compliance implications are direct. If subcultures fluctuate, then packages designed as if tradition have been uniform will systematically miss the populations most in want of intervention. Coaching have to be calibrated to the precise behavioral dangers current in particular groups. Incentive buildings should account for the pressures these groups truly face. Reporting mechanisms have to be trusted within the particular environments the place they’re most wanted. None of that calibration is feasible with out measurement that operates on the subculture degree. Compliance leaders who depend on combination knowledge danger designing packages for a company that doesn’t fairly exist.
Perception 5: Moral tradition evaluation is the brand new maturity benchmark and the price of ready is excessive
“Most organizations are neither in disaster nor at peak maturity. They’re someplace within the center, and that’s precisely the place complacency is most harmful.”
Casòliva noticed that, in observe, two kinds of organizations presently take moral tradition evaluation significantly. The primary are these working at excessive compliance maturity: organizations which have embedded tradition measurement into their governance frameworks as a regular self-discipline, not a response to any explicit occasion. The second are those who have suffered an moral scandal, a disaster, or a prosecution, and are conducting assessments as a part of remediation or below exterior strain. The circumstances of Uber and Wells Fargo are instructive right here: each corporations commissioned impartial moral tradition assessments following the crises that reshaped their public identities, and people assessments – publicly obtainable and broadly studied – doc in medical element what occurs when tradition is handled as background noise somewhat than a compliance variable. Additionally they doc how a lot floor have to be recovered, at what price, when that assumption proves flawed.
The argument Casòliva pressed most insistently was directed at neither of these teams. It was directed on the majority; the organizations that haven’t but suffered a disaster, and that haven’t but invested significantly in tradition evaluation, and which can be subsequently working on the belief that the absence of seen failure is a enough sign of well being. That assumption is exactly what the Uber and Wells Fargo circumstances refute. Tradition failures are hardly ever sudden. They accumulate, quietly, within the hole between acknowledged values and behavioral actuality, till the buildup turns into seen within the worst attainable method.
The prices of a broken tradition – regulatory publicity, reputational hurt, expertise loss, and the operational disruption of a disaster – vastly exceed the price of systematic, ongoing evaluation. Inside assessments provide pace and contextual depth; they are often designed and executed by groups with organizational data and are sometimes quicker and more cost effective. Exterior assessments carry a distinct and infrequently decisive benefit: independence and credibility. When a company should reveal the effectiveness of its compliance program to a regulator, a board of administrators, or a courtroom, the credibility of the proof it presents issues. Each the extremely mature and the crisis-stricken more and more fee exterior assessments exactly for that cause. The common group within the center has the identical want, and the benefit of performing earlier than that credibility is examined below strain.
Closing: From tradition as assumption to tradition as proof
The session at Cumplen’s 2026 ONE DAY COMPLIANCE Barcelona pointed towards a conclusion that’s more and more troublesome for compliance officers in Spain and throughout Europe to defer: moral tradition is not a gentle governance idea. It’s a regulatory expectation, a prosecutorial benchmark, a governance commonplace, and – when issues go flawed – an evidentiary query. The organizations greatest positioned for the following 5 years are those who deal with tradition not because the environment by which compliance operates, however as a variable to be understood, measured, and actively managed.
The course regulators, prosecutors, and governance our bodies are transferring is constant and accelerating. Spain’s Legislation 2/2023, the CNMV’s forthcoming 2026 governance revision, and the EU’s due diligence frameworks aren’t remoted developments. They mirror a shared judgment that compliance effectiveness, not compliance existence, is the operative commonplace, and that tradition is essentially the most dependable proof of the distinction between the 2. The organizations that construct that proof systematically, earlier than they’re requested for it, will discover themselves much better positioned when the asking begins.
Discover out extra
LRN’s Moral Tradition Benchmark International Version offers data-driven insights into the behavioral realities of organizational tradition throughout industries and geographies. Obtain the report to grasp how your program compares and the place the clearest alternatives for strengthening tradition infrastructure lie.
To debate how these findings apply to your group’s compliance programme, together with the way to design or fee an moral tradition evaluation, contact our staff. LRN’s ethics and compliance advisors work with organizations throughout Europe and globally to translate tradition measurement into program enchancment.
