Context

A multi-national bank implemented a digitised approach to managing and reporting on conflict of interest within the Corporate and Investment Banking division. The purpose was to ensure compliance around deal making and to shift away from the use of excel spreadsheets to manage conflicts of interest. The change included the introduction of software to manage conflict of interest, treating customers fairly, and meeting requirements defined by the Financial Markets Act.

Snap Stats

Change impact across:

• 8 process changes
• 6 regions in South Africa, Africa & London
• Duration:
  • 12 Month: Project Duration
  • 12 Month: Change Management Support
• Size of the Change: Medium complexity. High impact. High disruption.
• Change Management Resourcing:
  • Senior Change Manager
  • SME
  • Trainer

The Results

Established a centralised communication model for scale:

• Strategic Objectives Met: 5
• High visibility of outside business interests, signed NDAs and compliance breaches
• Users Trained: 486
• Triggered Conflicts: 654
• Efficiency Improvement on Turn-arounds: 5
• NDA Data Clean-Ups: 1261
• Updated / Signed NDAs: 225
• Deals Cleared for Conflicts: 198

The Approach

The change management goal was to drive buy-in to moving away from capturing conflict of interest related information in excel spreadsheets, to using a cloud-based system. The change management methodology used was the Triple A methodology: Create awareness, acceptance, adoption and sustainability of the change.

How:

• Created a solid case for change
• Mapped out stakeholders
• Created awareness of the change and demo’d the solution through awareness sessions
• Defined impacts across stakeholders (process, roles, systems)
• Identified primary metrics to manage and monitor CoI
• Leadership alignment with Exco and Manco
• Conducted significant end user testing and training
• Measured and reported on readiness, adoption and business results

Lessons from the Frontline

Critical success factors:

• Garnered Exco and Manco buy-in and support through demo’s and early wins
• A simplified and well defined case for change made the rationale easy to understand
• Measured the effectiveness of training and monitored adoption and compliance closely
• Created visible reporting of non-compliance with clear processes on how to manage triggered conflicts
• Had well documented as-is and to-be processes
• On-boarded a tester community to test the solution
• Project team member politics affected the project team’s effectiveness and a team alignment and cohesion initiative was implemented to improve project team cohesiveness
• People resisted implementation due to perceived need to capture historical data (which was done separately as a workstream by the project team)
• The transition of capturing CoI data from spreadsheets to cloud-based system started on an agreed date and was made compulsory
• Managers showed visible support of the initiative
• Managers were held accountable for managing CoI non-compliance

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