UGRs and Risk Culture: A Strategic Overview for ANZ
ANZ has undertaken significant work to strengthen its approach to non-financial risk—through the Oliver Wyman review, the enforceable undertaking, and internal initiatives like I.AM Amplified. These efforts have addressed formal structures, controls, and reporting frameworks. However, a critical gap remains: the cultural drivers of everyday behaviour.
The core challenge now is not structural. It is behavioural. Specifically, it lies in the unwritten expectations and perceptions that shape how people act when facing risk-related decisions. These are the Unwritten Ground Rules—UGRs.
UGRs are people’s perceptions of “how things really work around here.” They are rarely stated openly, but they determine how people behave—especially under pressure. The Oliver Wyman review contains clear examples:
Where staff believe raising issues doesn’t lead to action, the UGR is: “Around here, speaking up is pointless.”
Where leaders are perceived as saying one thing and doing another, the UGR becomes: “Around here, what matters is what gets results—not how.”
Where consequence management is seen as inconsistent, the UGR is: “Around here, outcomes override accountability.”
These unspoken beliefs drive behaviour more powerfully than formal policies. Unless they are identified and shifted, attempts to strengthen risk culture will continue to fall short.
The current context cannot be addressed solely through better systems. Culture change at this level requires a different approach.
Familiarising people with the concept of UGRs will help them understand how their personal behaviours contribute to the culture. What was previously unconscious for most becomes a conscious choice.
A UGRs Stock Take offers a different kind of insight to conventional surveys. It uses open-ended lead-in sentences (e.g., “Around here, when someone makes a mistake…”) to reveal underlying norms in people’s own words. It surfaces the real culture—quickly, clearly, and with no need for another program overlay.
This approach can align directly with APRA’s Risk Culture 10 Dimensions, providing behavioural insight into leadership, accountability, escalation, challenge, consequence management, and more.
In other high-risk industries, such as aviation, the same challenge exists. Safety management systems have been in place for years, yet critical incidents still occur. Why? Because it’s the culture—the UGRs—that determine whether the systems work in practice.
ANZ has built a solid structure. The next step is ensuring the underlying culture supports it. That means identifying the UGRs that are helping—and those that are holding things back.
Without addressing UGRs, the risk remains that good intentions will be undermined by persistent, unspoken norms. Addressing this layer is essential for sustained culture change.
What the Australian Bank Said...
We designed a 12-month program that provided the step-change the bank desired. The process involved the explicit articulation of the desired culture, a deep audit on the existing culture and the UGRs (unwritten ground rules) that currently governed the organisation followed by the development of a plan to build the new cultural agenda and launch the initiative through a series of events across the Australian organisation using employees as the champions.
This deep examination of the existing culture in play allowed us to break down the barriers that often hold leaders back from truly embedding the new vision.
What impact have you noticed since the program?
Vicki, a senior leader at the bank, says the key organisational cultures developed during the program are embedded and “still very present in the way we run the business”. They have noticed a particular uplift in accountability for results from their staff as well as better overall relationships and “at our best” thinking across the organisation. As a result, she says there has been “significant and sustained improvement on all our key indicators.” When asked how likely the organisation was to recommend our initiative, Vicki provided a score of 9/10, saying the UGR driven approach was “Simple and relatable yet provides very actionable and valuable insights. It creates an opportunity for everybody to get involved. It provides enough anonymity for people to say what they need to say, but also be heard and get involved in the plan for improvement.”
How would you describe the quality of the initiative?
Providing us with an NPS score of 100+ Vicki describes the experience as “simple and relatable yet provides very actionable and valuable insights.” Achieving their objectives for the program with flying colours, Vicki noted Steve has “an amazing ability to create influence with the executives.” The bank was particularly impressed by our ability to bring professional credibility and deep business experience to every conversation and the capacity to help others find their skills. One of the highlights of our initiative was our “strength in telling the story and bringing pizazz, energy and excitement to the program.” When asked how likely CUA were to recommend this initiative Vicki provided a score of 9/10.
Former CEO of Kmart
Former CEO of Kmart Australia and New Zealand Guy Russo, says:
"In the 1980s it was Situational Leadership and Ken Blanchard, and Body Language and Alan Pease.
In the 2000s, it was Jim Collins and Good to Great.
Now is the time for Steve Simpson and UGRs."
