A policy can tell employees to raise concerns. A speak-up culture determines whether they believe doing so will lead to a fair review and an appropriate response.

01

Make the signals and channels clear

Employees need practical examples of what should be raised: customer harm, possible misconduct, a control that cannot be completed, pressure to bypass a rule or information that conflicts with an important decision.

Leaders should also explain where concerns can go, including management, risk, compliance, human resources or confidential reporting channels. More than one path matters when the normal reporting line is part of the concern.

02

Respond to the message without attacking the messenger

The first response teaches the entire team what speaking up really means. A leader can thank the employee, clarify the facts, protect confidentiality where possible and route the issue to an independent reviewer when needed.

Taking a concern seriously does not mean assuming every allegation is correct. It means reviewing it objectively without retaliation or pressure to withdraw it.

03

Separate urgency from premature conclusions

Some issues require immediate containment, such as stopping a questionable transaction or protecting customer information. The final conclusion may still require records, interviews and specialist review.

Leaders should distinguish the temporary action needed to limit harm from the investigation needed to understand what happened and who is accountable.

04

Close the loop responsibly

Employees may not be entitled to every detail of an investigation, but silence can make a genuine process look inactive. Leaders should confirm that the concern reached the right function and explain, when appropriate, that action was taken.

Tracking themes across reports can reveal unclear procedures, unrealistic incentives, weak training or repeated control failures that deserve broader correction.

05

Measure behavior, not slogans

A speak-up culture is visible in how quickly issues surface, whether employees use available channels and whether leaders respond consistently. A rising number of reports can sometimes indicate greater trust rather than worsening behavior.

The stronger test is whether concerns are reviewed fairly, retaliation is prevented and lessons change decisions, processes or controls.

Sources

Read the primary material

Banking Explained prioritizes regulators, official publications and first-party announcements.