Inside Titan Wealth

Why modern compliance teams don’t say “no”

Titan Wealth Season 1 Episode 5

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Compliance has a reputation for slowing things down, but we’ve seen the opposite: the right governance, risk and compliance (GRC) culture helps a wealth management business move faster with fewer surprises. 

In this episode of Inside Titan Wealth, Mike Fogden sits down with Tiffany Roberts, Group Compliance Director, and David McGall, Group Head of Risk, to unpack what modern compliance looks like when it’s built on trust, judgement and real partnership with the front office.

Together, they talk honestly about the old “computer says no” stereotype, why it fails, and what replaces it. Tiffany shares how compliance becomes practical by connecting people across the business, guiding integration of new firms and turning regulation into workable steps. David explains why understanding front office pressures matters and how principle-based decision-making beats box-ticking when the rules live in shades of grey.

As Titan Wealth continues to expand internationally, the discussion also explores the realities of multi-jurisdiction governance, balancing standardised frameworks with local flexibility, and why transparency and trust remain critical when building world-class governance functions across different regulatory environments.

If the word “compliance” makes you think of box-ticking and blocked ideas, this conversation may change your mind.

In this episode:

  • The “computer says no” reputation of compliance
  • The importance of positive compliance culture in wealth management
  • Managing regulation across multiple jurisdictions
  • What “world class” governance, risk and compliance means in practice
  • The relationship between culture, trust and risk management

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For more information about Titan Wealth, please visit our website: www.titanwh.com

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This communication has been produced by Titan Wealth Holdings Limited. If you decide to invest, please remember that investment involves risk. Investments can go up and down in value, so you can get back less than what you put in. Past performance is not a reliable indicator of future performance and may not be repeated.

Welcome to the Time Wealth Podcast. Today I'm joined by Tiff and Dave and we're going to talk about all things compliance, but please don't switch off, it does get interesting. We're going to cover topics such as why compliance is a culture, not a department, and things to consider when applying compliance across multiple jurisdictions as time continues to grow itself internationally. This communication has been produced by Titan Wealth Holdings Limited. If you decide to invest, please remember that investment involves risk. Investments can go up and down in value, so you can get back less than what you put in. Past performance is not a reliable indicator of future performance and may not be repeated. Welcome to the Titan Wealth Podcast, Dave Tiff. Thanks for joining me today. Perhaps we could start by you both introducing yourselves for people that don't know you, please. I'm Tiffany Roberts or Tiff, and I am the group compliance director. Yeah, and I'm uh Dave McGall. I'm head of governance risk and compliance uh for the international business. Excellent. Well, thank you again for joining me. Um so let's jump

Beyond “Computer says no”

straight in then. Um this is a difficult one for you. People sometimes hear compliance and think maybe business prevention or computer says no. Um what's your perspective on that, Dave? And what would you say to people that might think that that's the role of a compliance function? Oh, I think uh that historically that may have been the case, and I think that um what we've always tried to do is kind of dispel that myth. Um and you know, I personally, and I know that the the the team at Titan have always really tried to promote a you know yes but uh culture, or um we want to be able to assist the business but and facilitate business, but but you know, in line with the the regulations and the regulatory environment that we operate within. Okay, great. And Tiff, when people hear your job title, then you've obviously just shared it with us. What do they usually assume you do and and what do you actually do? I think I guess what they they they think I do is is is police quite a lot and and say no, I I is probably most people's opinion. But um what I actually do is I I think a lot of the time I connect people, so introduce because I have to know a lot about all the the the whole of the business. So if I don't deal with it, then I can connect the right people. But also um, you know, I'll oversee in terms of integration, you know, I'll I'll work on that. So when we have a new firms, I'm one of the the people that go into our new firms that we're integrating, mainly because I have I can answer their questions, introduce them, speak about what I've been through when we've been through integration as well. So just kind of calm the the the initial fears that some people have as well. Obviously, you know, turning regulation into something practical as well. Um that's what I try to push across the whole of compliance as well, that you know, it it's all very well having the rule book, but you've actually got to put that into real life and and it and it depends on the firm that it that that you're applying the rule to, essentially. So, and I think that's quite key. And how wide is the remit of compliance and risk at a group level? It it expands everything really for so from initial onboarding and that would be from a new firm that we're integrating or a new client, so all the way through. So that the the the whole life of the client, and again through the firm of integration, so bringing them into to one of our firms that we already have. So and it does and I think that's one key point that you know, considering the risks, so that's where we're one of the the points I think that Dave and I always agree with is that you have to involve compliance and risk early on. So whatever it is, whatever issue you're you're you're talking about, I think that's quite key to to involve us early on, and that's where because because we go through the whole the the whole journey with either the individual, the team, or the firm. Okay, great. I can see you're nodding there. So what what's your perspective on that? Yeah, and I think it it goes back a wee bit to what you asked me earlier, Mike, was that you know uh the the perception of compliance and actually uh the remote of compliance now is far far more collegiate working with the business, working with the individuals, um, front office, middle office, back office. And whereas historically it might have just been, oh well, you know, that they're sat in the corner, there's a crusty old former police officer ticking a box. That's not the case now. And so I think not always, no, no, I wasn't a police officer. And but uh I think that that's that's one of the key factors. The remit is is is so broad that my day is often filled with just people coming up to me asking me questions and and you know, they how can we do this? How do we go about doing this? And I think just going back to Tiff's point was that the sooner that compliants are involved in those conversations and that we promote that type of environment, that you know it it just makes it a much more easy um environment for people to work with in. Okay, and but and just probing on that a bit further then, so what what changes when uh compliance really

The shift from gatekeeper to business partner

understands the front office rather than that back office that you mentioned previously? So what what are the benefits that delivers to us as a group? Yeah, well look, I I I've found, I think, in the last particularly in the last 10 years, that um front office individuals, whilst they deny it, and we all know those types of people that do, um there is a real there's a much better understanding of what what you know the environment in which we operate within and the the importance of regulation, and not seen as a computer says no um function or that the regulator's there to to to whack you over the head. It's more you know, we've we've got the ability to operate in this sphere, and how do we about go about doing that and operating in that sphere really well? And I think that's the bit that I've seen change in the last decade, I guess, is that front office understand the role that compliance plays more, and that therefore as a as a compliance professional or a risk professional, you have to then also it works both ways, you have to also understand the you know the pressures that the front office are on, and that means you know what is the strategy strategic outlook for the business. And you know, we we we are here to make money, you know, it's a it's we're we're we're a business that's um that's out to make money, and we need to help support the business in order to do that and achieve those strategic goals. Okay, great, thank you. And then Tiff, just expanding a bit further then, we obviously one of our clear objectives at Titan is to have a what we call a world class governance, risk and compliance function. When we say world class, what does that mean to you? So I think world class to me is standardization, but then I I applying it to the relevant areas, so internationally, obviously, because we we're a growing business internationally. So we have you know, we have policies, we have procedures that are standardized, we have systems, we have we have governance and risk and compliance systems that are across all of our entities. However, when we have to apply them differently for a different set of regulations, it's a much easier task to do because we have these set policies. For example, we have them at group. So it's it's easier for us to apply for the different firms rather than having a number of different policies all on the same topic, um, which we've then got to tweak. And that makes it hard to oversee, that makes it hard to audit, and it actually makes it more costly for the whole of the business as well. Okay, yeah. And is there an element there on world class around to Dave's point previous, the proactive versus the reactive element as well as I think? Absolutely. Is that something you think is important? It's something that I that I really push. You know, I think that's where where I've always I think people that you know that I I've my main base is London, and generally most people will always say, Tiff, have you got time for a chat? And it won't be that they won't have a fully formed issue, they won't, they won't know all of the details, but I'd much rather them, you know, come and knock on my door and say, you know, there's just something that I um we're planning or we're thinking about, or there might be an issue here. Can I talk to you about it? And then you know, we can actually

Why positive compliance culture matters

start digging in and being involved with the with the issue, or actually, you know, if we're if we're looking at something, uh a new part of the business or you know, a new regulation that's coming into play, something that we've got to actually get involved in. Um that's that's where I think we really want to push because we we need to be involved. I think you're you'll hear this topic quite a lot that you know we keep on pushing that that the earlier compliance are involved, the the greater we can actually help the business, quite honestly. And that's how we can actually make this this gold standard governance, risk, and compliance. Yeah, great. Okay. And when we say world class, Dave, does that mean worldwide or is that something different? Um it's a good question. Uh, and I think you know, as as we evolve as a as a business, um the the global footprint is increasing. Uh a fair old lick, I would suggest. And I think that's that does drive, you know, you know, this this world class uh ethos, I guess, and the it it comes back to culture, I think. And as Tiff alluded to, the the the the standardization and the you know uh uh the approach of look it we we operate in various different regulatory spheres and different regulatory jurisdictions, yeah. All of them have their own subtleties, quirks, and and and different aspects that we have to be mindful of. But if we can, wherever possible, adopt a higher standard, providing that it doesn't impact you know the the the business objectives of of that jurisdiction. So we don't want to stifle business, but what we certainly do want to do is is provide a standard that you know the senior management can actually buy into and understand, and that they know the the the environment in which they're operating within, yeah. Which which which then sings to the um the business development plans and the strategic plans for the for the wider group. Then that also helps staff members as we all operate together across the globe because we know the the standards that are expected of of individuals, and then you know that promotes the culture. So yes, the ambition is always there to be you know world class and and world leading in terms of you know all of our governance, risk, and compliance functions, but but it really does come down to you know how do we go about doing that? Is it is it still appropriate for the jurisdiction in which we are operating within and and making sure that you know where possible we've laid a blanket of sort of good governance, good compliance over all of those areas? Okay, yeah, that was something I was actually keen to jump into a bit more on the what the the fact that we are an international business ever increasing our footprint. How do you approach different regulators with different you know expectations? That that's obviously a daily challenge, but what come more of a challenge and more of an opportunity for our business? So, how do you go about that? Yeah, I I mean uh yes, so I think both of us have we've we've we've visited various regulators over the years. We've had significant interaction with our regulators, so across not only the Channel Islands, but Isle of Man, uh the UK obviously TIFF is the the leading expert in that field, but also down into the UAE, um, into Dubai and further afield,

The “yes, but” mindset and solving problems early

Canada, for example. Um I think it's safe to say that all regulators will want their voice heard or to be considered at the you know at the forefront. And I think that's understandable. Uh they've got a job to do. But I think it's always comes down to transparency and what is it that we're trying to achieve? And what as a as a as a business, what onus do we put on our regulatory obligations and uh you know our compliance functions? And I think by and large, my experience has been nothing but positive because providing that you do have that transparency, that you do bring your senior management team and your staff along that journey, and that you can demonstrate, you know, through positive interactions with your regulator, you know, I I always use the word it's a kite mark for all of our stakeholders, for our clients to feel confident that the senior management team take regulation seriously, and that therefore, you know, as custodians of their valuable assets, that we actually, you know, we take that seriously, and that there's there's a good degree of governance that oversees how we monitor and how we look after our clients' assets, and I think that's fundamental. Okay. No, I completely agree, but I really do. And but I also think that um, you know, with our regulators, obviously, you know, if I say say like the FCA is that is the gold standard, and that's where we're trying to bring everyone up to. We don't we don't want to stifle business, but also I think if we can show the regulators internationally that we are always putting our clients first, you know, and we we are using what our any decisions that we make, we make them our client is always at the heart of it. Then I think that that's you know, that we document it, we we've tested it, it's it's not a knee-jerk reaction that we're doing. That then I think that we can always bring, as you say, bring the regulator along. It sounds corny, but bring them along with the journey, quite honestly, and and show them what we've done, then uh from from my experience, we we, you know, if they are fully up to speed and they can understand it and they can see the process we followed, they've always been fully supportive. Definitely. Great. I'm really sorry to interrupt the podcast, but I just wanted to say that if you're interested in a career at Titan Wealth, why not head to our website and have a look at the career opportunities that we have available, or there'll be a link in the show notes below. Now back to the podcast. And slightly bigger question, how how would you define success then, Tiff, for a a regulatory and compliance function? What what's your kind of how when you go to bed at night and think, is it a good day or a bad day? What's your assessment criteria? How are you how are you how are you assessing that? Um I think how how I assess it is, you know, I I think particularly with I've what I really do find it a success is that if people come to me with problems, you know, I think where where we have issues, if they're not telling me problems, then that really is that's a conduct issue, quite honestly. You know, that's a culture problem that we've got. And so, you know, anyone knocking on my on the door just saying, Tiff, I need to talk to you about this, we've had this error. Errors happen, quite honestly, and they do. There's nothing we can do about that. But what we can, we can learn from it, we can mitigate it so it doesn't happen again in the future. You know, no one's gonna have their head chopped off. We're not about blaming people because I'd much, I'd be far more worried if they didn't come to me with issues, quite honestly. Also, it would probably do me out of a job. So, you know, we've we've got to find these these reasons to to mitigate against issues that are raised.

Embedding governance into strategic decision-making

If they're hiding them and they're, you know, we won't tell compliance, we won't tell risk, we won't involve them. That's when we've really got a problem. So, you know, when I'm pulled into different questions and most of my day isn't truly compliance, you know, going through the rule book, looking at Cobb's rule 4.2, it's it's it's a much wider than that, quite honestly. You know, it's it's higher level and it's thinking out, you know, working through problems, discussing with senior management, you know, Andrew and James, they'll come to me, they'll give me a topic, quite honestly, and I'll I'll have to go away and and think about it and you know, do my research, think about what what the issues are, who we need to involve in the business. So I've probably gone around the a little bit around the garden in that explaining what I find successful. But it's being involved, quite honestly. You know, it if if I'm not having people come to me all the time saying, Tiff, have you got five minutes? I generally don't have five minutes, but I will always make five minutes for people to come and talk to me because if they're not talking to me, then that's when the real problems are. Yeah, okay. Is that the same for you, Dave? Yeah, yeah, it it really is. And I think you know, a a good day is where you know you've had, and I think this is again, we come back to culture. It's a you know, people use it for as a buzzword, but for for me, a really positive compliance culture is exactly as Tif suggested, is that people aren't afraid to come and ask you anything. And it and it quite often, as you rightly say, it's not about you know getting into the minutiae of the of of the regulation, it's more the you know, the principle-based piece. And how do we do this? Should we be doing this? And and the fact that, you know, as Jay, you know, you're quite right as well, Tiff. I mean, we we're lucky to work in uh a company that really does promote a positive compliance culture because we are involved in um a lot of the conversations at at very early stages, and people will want to get our opinion on things, which is great. Um, because I, you know, 15 years 15, 20 years ago, I just don't think that was the case. And I think it it very much is now. So there's value to be had uh uh with with involving compliance and risk in in early stages. But a really a good day for me is you know when you've you've got particularly something, somebody from the front office comes down, wants to have a chat, and they're trying to figure something out, and we you know sit down, we chat it through together, and we actually figure out the right way forward, be that with the fact of they're looking to onboard a new client, but it's in a jurisdiction they're not sure of, we would sit down and we'd go through that um and we'd find a way through it. And and and more often than not, when there are question marks about, well, uh you know, we've we've had this inquiry, but I'm not quite sure about it for the following reasons. You kind of go, well, you're you're on the money there, right? And it's that's why. So that's a really good day for me because I feel like between front office, middle office, and compliance, we we're all we're we're growing together and we're on the same page. So the the strategic outlook is is is is being aligned, and I think that's that's a really good day for me. Very good. So we talked about the end of the day. What about the start of the day? So what f what fires you up? What gets you out of bed in the morning? What what is it about your job that you love the most? But maybe come to you first, Tiff, on that. I'm very lucky. I love it. I absolutely I I love that no no two days are the same. You know, that everything changes. Um, you know, you you'll have your list, and and this does sound corny. You have your list of of things you're gonna crack on with, you're gonna clear, and then something happens, and or even just some oh, we had a meeting and something's been raised, and well, I need to look into that because that's an emergency. So that's gone to the top of the list. Or, you know, even like

Risk, regulation and scaling internationally

dealing with my team, you know, it it's a much bigger, bigger, bigger remit now. You know, I I I'm very lucky that you know, I get to visit the different offices, I get to speak people to people. It's I I'm it no two hours are the same. So it's and and it isn't purely, you know, I've I've been in compliance for for quite a while, and that's what I really enjoy about Titan, that you don't do the same job every day, quite honestly. It's you know, you change and also you learn so much, you know. I think from from when I first joined to where I am now, it's I remember when I was you know sitting down with Damien and initial conversations I'd have with him, and you know, it and it does there there are nervous points in where you think, oh my god, I've never done that before. You know, that that's completely new for me. Yeah, so it stretches you. And it really does stretch you, but now I've done it and I'm quite used to that now. You know, that's just something something that I've added to another string to my bow, quite honestly. So it's that that's what that I love it, that the change and the fast tempo as well. But also, sorry, just to another thing that I've also worked in firms before that it takes so long to implement a change that there's you know, it has to go up to committee, committee meet up to the board, and then a decision is made or a question's made, that gets fed back down, and you feel as though nothing actually happens, and it's really frustrating when particularly, you know, my team will come to me or or different people, and and and we need the change to happen because of something, and and it needs to happen quite rapidly. You know, we can make that happen if if there's a reason for it, and it does, you know, we we don't need jerk at all, you know, there's thought in it, but if change needs to happen, it it's not like moving an oil tanker. Yeah, great. Dave? Yeah, um it's the teamwork, I think. Okay, and that's not just within our own teams, and it's it's been brilliant since joining Titan 12 months ago um when we were acquired. Um we've we've just had you know access to so many other different environments, jurisdictions, outlooks, different people, and you know, there is a really positive team feeling about this. There is a diff definitive direction of travel. And then being able to bring our own teams along on on that, uh along that, you know, using the the the tagline journey again, but but it really is it it it it really is, and and that's uh that's what gets me up in the morning and seeing the team develop, um having new opportunities, no, no two hours of the same, 100%. Yeah, I love that. People say no two days the same hours. Two hours, yeah. And and you you know, you you sit down with your list and that goes out the window within about 15 minutes, but but there's a there's there's there's a beauty of that, you know, it's because it it's mentally stimulating. But I really do like seeing members of the team succeed and you know have been been empowered to figure things out themselves, watching their development. That's what that's what gives me a real buzz. Uh and that's the same for you know, like I say, it's not just within our sort of our own uh compliance and risk teams, it's it's it's across the whole bit. And seeing other people develop and seeing people grow and being able to have the opportunity to grow within the Titan group. I think that's really, really special. Great. Thank you. Um so just moving things on a bit then. Well we know obviously Titan that one of the massive benefits of being within Titan is it's dynamic, it's fast-paced, it's energetic, it's entrepreneurial. How do we well how do you stop compliance from being from suffocating that growth? You know, it we talked before about the balance needed, but just talk to me a bit more. Maybe, maybe Tiff, start with you. Um you know, is there a tension between ambition and regulation? And how how does that usually

Managing compliance across multiple jurisdictions

show up and how do you manage that? I think I think there can be, you know, there can be a tension, and also it can be a little bit of a fear factor as well, I think, which you know, and it takes a while to to get used to that for some people, you know, if they're not comfortable with that. But again, I'm harping on this again, but it it is early involvement with with compliance, I'd say it's it's a real key point. You know, we we don't have to be involved throughout every single meeting or every single point. But if you involve compliance early, that you know, they can step in and go, All right, have you thought about XYZ or let's work on this together? And or they may say, You have these couple of meetings or get to this point and then we'll get involved again. You know, it's not a point apart of you know us policing and and you know watching over people's shoulders. It's just it's much better for for us to kind of go, Oh, have you thought about this or have you thought about that? Okay, at that point, rather than at the point of sign-off, when you're coming to compliance, go, oh, someone's got to look at it, and then you've got to be the bad guy and go, Well, you haven't thought about this, and you know, hang on a minute. I know everyone's ready to go live, but Tiff's ringing the bell and everyone hates Tiff. So you that's where it it's always better to start to involve compliance earlier. And I think there is a problem, or not a problem, but I think that's where the two rub against each other that you know it in terms of that that that things want to move quickly, but then you do have the compliance where you've got to prove it, you know, it's got to be documented, it's got to be written down, you know, we've we've got to perhaps bring the regulator along with the journey a little bit. Okay. Involve them. And that so there are areas, you know, if we're using new tech, sometimes that can be grey areas where you there could be conflicts. It's it's all of those sort of areas where you know that they do have to be handled. It's definitely rarely do I say no, and and if I am saying no, then it's a good reason to it'll be a serious reason. So, but it'll be right, we can do that, but hang on a minute, let's work on this, let's do this, and you know, and we'll sit down and and work with you on that. Yeah, okay. But uh, but I think that's where you know the issues can arise. But compliance, the door's always open. Yeah, maybe we'll say something. And I think I think that it there's you can look at it the other way as well, in in as much as that you know it's our obligation to be able to educate the the the rest of the business as well, in terms of the importance of of that, and and and um what I mean by that is um if i if if if we're designing a framework in which to operate within the regulatory sphere, wherever it might be, and you you know you have to kind of it it's not often you build anything in finance, but in our world we do, we build these frameworks with you know that that sets out from a strategic business plan down to you know the the key artifacts and documents that we use to monitor the business and to to to support the business, and then obviously then the policy network as well. So building all that out takes time and you know quite often it it's it's a struggle sometimes to able to demonstrate the value add that that can have to the business. But but of course, then when there's an incident or you know somebody makes a mistake, then you can see how that framework reacts and you can see actually how it actually protects the business. And I think that's incumbent on us to be able to show the wider business what that means and why we're doing that. It's not a case of we're we're stifling or putting a straitjacket around the business. It's quite the opposite. It's kind of saying, well, the business wants to travel in this direction. How do we get there? What do we what what systems and framework and controls can we put into place that supports that, not stifles it? And I think it's as it's as much incumbent on us to be able to show that to the wider business and to the senior management and to everybody else that you we're building this pathway to support you and ultimately support and protect our clients. And that's fundamentally why we're here. Yeah, yeah, great. Tiff, I know you know you mentioned before

Standardisation vs local flexibility

about this um involving you early and that you always prefer that rather than ringing the bell at the 11th hour. Also, I know from working with you and the team, things are rarely black and white. So you know, sometimes people think it's a straight yes-no. Most of the time it isn't. No. So it's this flexibility within a framework, and I know that's something you're really passionate about. I really am. Yeah, it's something that I've I think throughout all of you know, my bosses previously, historically, I've my my great bosses have always trained in me. You know, it it we rarely say no. It's always, you know, right, you might not be able to go from A to B, but we can go from A to F back to B. But it's but that's again the point of working with us on an early point, honestly, rather than you know, plowing ahead thinking you've got everything right, yeah, and then one of my guys somehow hears something or they're in the kitchen and no one's heard anything, and then they have to get involved. And then compliance come across as the bad guy, which they're absolutely not. They're they're there to help you and keep you safe, essentially. They're looking after the client and we're looking after the business. Yeah. So, but that it it's not, it's always, it's always there's always a grey area, it's not black and white. And you know, I I think people do think that, you know, oh, you adhere to the rule book, but the rule book has there's a lot of nuances in the rule book, quite honestly. So, and it is down to interpretation, and again, it's uh applicable to different firms in different ways. Yeah, and that's where you know you you have compliance, you have the compliance team work with you because they know what they're doing and they're there to to look after you, quite honestly to you know, because if you could tick that box and say, I've involved compliance, we're good there, then it's joint accountability. You've done your bit, we've done our bit, and everyone's a winner. Yeah. I'm really interested within that though, how how do you make judgment calls then along the way without slowing things down? Because obviously that's if it is flexibility within a framework, there is some subjectivity there, isn't there? There is how how do you approach that? And again, I think that that's it it takes it, I guess it takes quite a some time to be honest with you. And again, say I'm bored of hearing myself say this, but it is it is the early start, it's being involved early because then actually the the compliance teams working on the the project or the issue or the question, then they fully understand. So they've actually got a bit of time. There might be a point where they have to go away and have a think about things, and you know, they'll come up with solutions, but also it's a case of working with the front office on a solution rather than mandating, you know, that's something that none of the team do, you know, it's it's not a right, it's this way, it has to be done this way, and you've got hoops to jump through because that's just not gonna actually, you know, that's not gonna our fast-paced business just won't work that way, quite honestly. Okay, so if you involve compliance and you know they'll work with you, then we'll find solutions together because again, it is listening to the front office, you know, they'll feedback, they'll provide information, and then and compliance work with you. So it's it it's a case of just working together. Yeah, great. Um, Dave, you mentioned culture earlier. I was keen to dive into that. Obviously, um, a large part of the reason we're doing these podcasts is to help connect the group up and start to talk about you know, one title and showcase some of the different areas across the business. But I know integrity is really important to both of you as part of you know our cultural framework. What does that actually look like day to day for you, integrity? What how would that show up? What would it mean in practice? And what does it mean in practice? I think we've we've alluded to a few things um whereby I I generally feel that we have a very compliant culture

What “world-class” governance actually looks like

in in across the group. I I really do feel that. And um and and I think where you we we would talk about integrity is it's integrity from uh from top down, so making sure that the board of directors and the senior management team um are being seen to you know carry out uh business activities in in a way that where you we talked about the shades of grey within uh uh the regulatory environment. There are all the shades of grey shades of grey, but but being able to take risk-based approach that that align to you know the the ethos and the integrity piece um is really important. And people see that from a from a top-down uh from a top-down approach. Then you know, individuals and staff members on a day-to-day basis making considered you know uh decisions that put the client first, fundamentally, and then the business second. And quite often then it that there might be occasions where the business has to come first and then actually client demands come second. But as long as we're thinking that, you know, what are what are we here for? We're here for the client and actually making informed decisions, risk-based decisions, um, that we can all put our hands on our heart and say that was the right decision to be made at that time and it was made for the right reasons. I think that's fundamentally what you know comes back to, you know, a good compliance culture, a good environment where people do feel that there's trust within the compliance team and within the senior management team, and that they feel that they they those individuals are making the right decisions for the right reasons. Okay. Um, and Tiff, on that theme, obviously within that piece around integrity, there's personal judgment, there's personal accountability. So rather than thinking the compliance department exists and therefore they they're taking care of all that, I can do my job. What would you say to that in terms of people's personal kind of responsibility? Yeah, it's something we were talking about earlier. I think it's it's it's joint accountability. You know, that it times have moved on. It's no longer, you know, oh, if compliance of have seen it and ticked the box saying it's not my problem, Tiff's going to prison. You know, it's it's not that at all. It's it's you know, you're you're being the grown-up as well. You have your role, you have your job, but you've involved compliance and we've reached a decision together that individuals should feel confident that that issues like these are raised, and and when problems do arise, because they do, then they are actually, you know, they're aired, they're not brushed under the carpet. We have you know senior management down discuss these issues and and we fix them. They're not that they're not just ignored, you know, because culture is important to us. Yeah, and and just to support that, um within our you know, with our within our various committee structures and our governance structures, I think it's really important. We we we often invite other members of staff to attend those, not necessarily to participate unless required to do so, but to kind of observe and see and understand better. Because I think that's that's a really good way of understanding what the business has to has to go through uh on a day-to-day basis and and understand the risks that we face as a business. Uh, and that's been really, really positive. You know, people from the outside of the governance risk and compliance world that come to those types of forums and they they could they can contribute. Um but I we we've used that as a tool to give people you know a better understanding of what the you know the the various different risks that we face as a business and how we um then make an informed decision on how we approach them and and and the processes we go we go through. So that comes back to transparency, it comes back to trust. You know, I think it's it we have to have trust, trust that the senior management team are doing the right things by the business, trust that the compliance function will be here and it's an open door, it's an open door policy. We want people to come and speak to us, and then trust from the client's perspective that we're we're we're doing the right thing by them and that we're looking after their assets appropriately. Yeah, that's great. I mean, I think for me that that personal accountability and thinking that compliance is a is part of our culture, right? It's not a department, it is something that we all have to be thinking about and conscious of, and using, you know, having integrity is a useful guide for that, right? Where where there aren't formal rules in place, acting with integrity is a useful benchmark and useful barometer to say actually is it the right thing to do or not? Does it feel the right thing to do for clients or for that part of the business? I think that's why I'm really keen to, you know, for for all of the compliance team to be to be present. So, you know, on on the office floor, they're they're always around, you know. Because if I I also I think the more people know me, the more you know comfortable they are to come and talk to me or talk to the team, then if I'm present, they then nothing's hidden, quite honestly. And as you say, exactly that, that you know, it is an open door and compliance are involved throughout the whole business. I just have to say you've got to be careful, your door will be in inundated after this podcast. It's a saloon door. Careful what you wish for. Oh, I just support that, and I you know that uh everybody knows that um I I really promote getting up off your seat, going and speak to people. But if you're going to send a big long email that you know it's gonna take people two days to read, as opposed to doing that, pick up the phone, go and speak to somebody, be present. Well, that's what we want. Hopefully, the compliance team will and uh and the governance team will be present around all of our offices and jurisdictions. But I think that's so important for building the the trust and and and building the relationships because our front line our frontline defense is actually our front office. Yeah, it's the people that interact with the clients on a day-to-day basis. They are they are compliance. Absolutely. They're the people that are responsible, they're the people that are so close to the the action that they're on the call face, um, that they're you know doing the right thing by the business and and and working hard to grow the business. But equally, they're the people that have got access to you know the most risk because they're dealing with the clients on a day-to-day basis, you know, and and so that for me is fundamental when we talk about promoting a good compliance culture is that people understand their regulations, they understand the environment in which they operate within, but they also kind of say they might make a question, a form of question on the head saying, didn't really like what that client has just said to me. I'm gonna go and speak to TF, I'm gonna go and speak to Dave, I'll speak to one of the members of the team, yeah, and just chat it through and and allay those fears or allay those suspicions. Or it gives them an opportunity to kind of actually raise a uh, you know, a a really good uh a really good catch and and and and uh and an issue that might need to be dealt with. Yeah,

How to engage compliance early

great. And you obviously talked a bit both on this podcast, both of you, about the importance of involving compliance early, and you know, you've you've got uh you know, people hanging on your every word on this podcast desperate to understand what you're gonna say next. So what if people are gonna come to you early, what what what's the how would you want them to engage? What's the best way to engage? You know, if they're gonna bring you a problem or a question, is is there a kind of pro form or thing they should be thinking about around how best to approach and what information to bring, or is it literally just if something's on your mind, have a chat? Take us out for dinner. I think just yeah. Lovely. Steak, that'll be good. Um, I think I think the more people worry about you know what information I'm gonna give you, you know, have I got all the facts, have I got all the details, then they're gonna they they're gonna miss a boat, quite honestly. You know, I'd much rather them come to me and go, Tiff, I don't know all the details. If there's a problem, you know, I don't know all the details. This is what I know so far. I can ask my questions, you need to go and find out who, what, why, where, when, how, you know, and then come back and we'll we'll do some more, we'll get involved. But also, you know, we're thinking of this new product, we've got this new client range where we're thinking of a new jurisdiction, all these different things. Rather than sat there kind of navel gazing, essentially, thinking too much about the issue, just come and have a chat. That's all you need to do, you know. And if you if you know, you can

How modern compliance careers are changing

generally always get hold of one of us, quite honestly. You know, if I'm not at my desk, it'll be because I'm in a meeting. So you can drop me a Teams, you can phone me, you can, and the same with the team, someone's always around if you want to go and speak to them face to face. Yeah, I absolutely wouldn't, you know, if please don't think about filling out a form or something like that, just because I think whilst you're worrying about that, what you need to put in and what you haven't, then you know, you're thinking too much about it. I'd just rather, because we can it's not gonna be the only conversation we have, probably about the issue. Yeah, so let's just kick off. Yeah, great. You agree? Yeah, come and have a chat, you know, um, pick up the phone. Um there's always somebody gonna be there to answer. Um, but that is you know, you're you're 100% right. If if a problem shared is a problem halved, and um and it just uh like I say, it just goes a long way to allay fears or actually just to be able to, you know, offload on where they're currently feeling and how they're how they're feeling about things. And and and likewise, um, you know, there's there's always gonna be frustrations because you know, we are a fast-moving business, we're an entrepreneurial business, we want to keep uh business flowing. And sometimes, you know, the machine does doesn't move as quickly as people would like. So that's just the world that we live in. But I think by and large, um, because we do understand our own um strategy and where we're going and the types of business that we want to be doing in all the various spheres and the service lines that Tyson offer, I think that we can move quite quickly. And um, because you do uh end up speaking with decision makers very, very quickly, yeah, they can make those informed decisions, but but frustrations will always be there. Okay. But if they're you know, don't hide in uh or or drown in a two-page email, uh, trying to cover off as much as you can. Pick up the phone, chat it through with the team, chat it through with TIF. Come and even better, come and come and speak to us because we're probably reviewing a policy that we want to be saved from anyway, or knee deep in a business risk assessment of some kind. So yeah, come and have a chat with us and save a life. Yeah, great. And just for the benefits of the people watching, how does that openness help with our relationship with the regulator as well? Just bring that to life because that that's obviously really important, isn't it? It absolutely is. I think it really helps because you know we we whilst the the regulator is slightly different internationally versus onshore, that you know, we we're not as lucky we don't have you know a direct contact. But we are we are growing, obviously, as a firm, and we have we are seeing the same people at the FCA through our different firms that we have. So, you know, and they're they're connecting the dots, they're they're working out that you know that we are this bigger entity, quite honestly. And so our communication, so when they're asking questions, even their understanding that, oh, you don't do that in that firm, but you do do it in this firm, and that then we can talk about things that are coming down the road, you know, and also what we've applied here, we've applied in a different firm as well, because and it just shows that we've got greater oversight, you know, that we've got this group, we have governance, risk, and compliance at group. So again, as I've said before, you know, we have these policies, we have these systems at group, so we have uniformity, which gives it the the regulator comfort because they're thinking, right, so you've got you know policies in place, you've got committees in place, you've got, you know, that there's good, strong governance, you've it it just works better because the more we know, the more we can actually give to the regulator. Yeah, and and they feel that you know that they just take comfort from that and they've got confidence in us, which ultimately means that you know we don't have the the continual questions from them, we have the check-ins, but you don't have the four o'clock email from the FCA. I've been there on a Friday afternoon, thinking of Christmas Eve. That's I've been there as well, had that, and and you think, oh God, right, everything's you know, all hands to the pump. That's Christmas ruined. So, you know, it it it it pure it helps us if the business help us, quite honestly. Yeah, great. Okay, we're we're gonna close now. Um, as I said earlier, we're doing a series of these podcasts to obviously

Building trust, openness, accountability and one Titan

share across the group all of the great work that's happening and connect the business up, all very much around the idea of one titan. I'm just really interested from both of you what one titan means to you. So maybe Dave, I'll start with you. What is it? What does one titan mean? It maybe in terms of day-to-day behaviours rather than a slogan, what what does it mean to you? Yeah, and I think it's it it's going back to that trust piece, it's going back to the integrity piece. One Titan is that it doesn't really matter whether you're in the Guernsey office, the Jersey office, the London office, UAE, Kettering, or elsewhere within the group, north of the border in Scotland or wherever you might be, is that there's an expectation of how we behave, there's an expectation on what we're trying to achieve for our clients, and there's an expectation on how we go around doing uh and operating our business. And I think that for me is what one tight is all about. We've got a strong brand. I think we're we're all getting behind that. I think that's a really important, um, that's a really important thing to give us the identity and uh and and and being lucky as as Tiff uh is as well, that getting to travel to the other offices and being able to, you know, uh champion that that that that culture piece um uh under the One Titan um brand, I think is that that's what it means to me, is that is that it's promoting good behaviours, doing the right thing by our clients, and and having a bit of fun along the way, actually, making it making it enjoyable. Great Tiff. One Titan, what does it mean to you? I I do agree with with Dave, to be honest with you. I think it's you know, we've got these collection of firms, but we are one firm, and that's where I think we we really need to push in 2026 that you know it's it's something that I'm really feeling now. We're actually you know integrating the firms, we're you know, we have we have uh we have group conduct, we have group compliance, we have so we are all singing from the same hymnsheet, essentially. You know, it's it's how we we we view the business, and as you said, you know, it's you know, we're doing it, we we're thinking of our clients, we're putting them first, we're doing it in a compliant fashion. But and as you say, as well, we're we do have a good time doing it as well. You know, it's it's not drudge. I we've both said that we enjoy our jobs, and it it it that that's what I'd say is what is one tighten to me. Brilliant. Thank you both. Well, that draws us to a close. I look forward to the ticketing system that's going to be needed to manage the inbound demand for both your uh diaries. But thanks for taking the time to join us today and um have a great rest of the day. Thank you. Thank you very much. Cheers.