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The Financial Reporting Council

Supporting the Financial Reporting Council with an independent research study on culture across some of the UK's largest corporate enterprises and Plc's.

The Challenge

The Financial Reporting Council is an independent regulator in the UK and Ireland based in London Wall in the City of London, responsible for regulating auditors, accountants and actuaries, and setting the UK's Corporate Governance and Stewardship Codes.

How boards and executive teams influence, shape and embed culture in their organisations is critical to sustainable performance. Dragonfish’s leading culture research (Cracking the culture code) highlights the importance of alignment to a vision, purpose and set of behaviours on an organisation’s overall performance and compliance, and the role of leaders and managers in manifesting the desired culture in its operations and relations with stakeholders.

The FRC recognise culture, integrity and diversity as central to the Corporate Governance Code. Dragonfish were engaged in 2021 by the FRC as subject matter experts in organisational culture to support them build on their 2016 study and produce a comprehensive research paper on investigating culture in companies, through a series of interviews and roundtable events with FTSE 100 Chairs and CEOs.

The research aimed to understand:

  • The tools, concepts, and frameworks used by boards to frame and support their companies’ internal discussions on culture.

  • The practical internal approaches to measuring culture, embedding and implementing culture change and reviewing the impact of culture since the FRC’s first report (2016).

  • Obstacles encountered by companies when promoting their desired culture and how these have been addressed.

Example insight includes:

“For many years culture and Board conversations were directed by HRD using employee insights. Now it’s much more strategic and imperative for sustainable success. You need to align on what you should be doing, capabilities, customer, environment and communities. Even understanding our brand in different markets has a cultural angle”


David Nish, AC Chair (2021)

Vodafone Plc 

The Solution

We carried out 24 in-depth interviews with CEOs, Chairs and NEDs of predominantly FTSE listed companies. All interviews sought insight on the following three research questions commissioned by the FRC:

  1. What externally sourced information, guidance and tools/concepts were Boards using to frame and support their companies’ internal discussions on culture?

  2. How have companies’ internal practical approaches to measuring corporate culture, embedding (implementing) culture change, and reviewing the impact of that change evolved in the five years since the FRC’s 2016 report?

  3. What obstacles do companies encounter in promoting the desired corporate culture and how have they been (or how can they be) addressed?

Interviews were carried out by senior dragonfish research consultants, with a background in shaping and designing culture across multiple industries and business. Additional specialist expertise in the field of Auditing, Finance, Executive Leadership Coaching and Research were also used by dragonfish in both the interviews and the production of the final interview report.

Using a thematic research approach, a set of overarching themes were identified from the interviews, alongside findings relating to the three research questions commissioned by the FRC.

Roundtables were used to probe into the emerging insights further with leaders and culture practitioners. We particularly focused on the core insights in these sessions, to dive deeper and strengthen our findings, identifying real world examples.

The companies we interviewed included: - rolls_royce_PNG34.png

The Outcome


We prepared a final report on Culture in Companies, reporting on themes such as:

  • Corporate culture was supported by developing and communicating against clear culture blueprints and frameworks.

  • Purpose provided a clear platform; it was the foundation of culture, but needed to be backed up by the company’s day-to-day reality.

  • DEI was seen as a cultural enabler; was increasingly seen as a driver that helped shape culture, unlocking talent potential and creating environments where people could speak up safely.

  • While CEOs were an important lever for culture change, it is with middle managers that critical work should take place - this was where culture change could be influenced.

  • The role of Boards was clearly evolving; some were beginning to, or had already begun to explore conversations about culture.

Our final report was used as a basis for the FRC’s report: Creating Positive Culture: Opportunities and Challenges, launched in December 2021. This led to the FRC creating a podcast series ‘Creating Positive Culture’ and a dedicated resources page on the FRC website.
FRC final report.PNG

“We would also like to thank Dragonfish Consulting for the considerable work it carried out on our behalf which fed into this report. This includes conducting 24 interviews with company Chairs, CEOs and NEDs, and also contributing significantly to the conceptual analysis contained in the report.”


The Financial Reporting Council


If you'd like to understand this project or our approach in more detail,

email or call 023 8082 8505

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