There is much talk of ‘compliance culture’ and, latterly, ‘compliance ethos’ and it is generally assumed that this is a good thing, by definition. This paper suggests that the existence of a compliance culture is never in doubt — all firms have one, the question is what is its orientation? The paper proposes three possible states of a compliance culture and suggests some qualitative measures of a positive or pro‐compliance culture. The paper is an extract from a submission made to NatWest Life's Audit and Compliance Committee in February 1995.
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