An Introduction to Outcome Based Cooperative Regulation (OBCR)

You can now download the new 9 page Introduction to Outcome Based Cooperative Regulation (OBCR) on SSIR and on INDR – from Christopher Hodges OBE at University of Oxford – Centre for Socio-Legal Studies; Faculty of Law.


OBCR is a model for achievement of common purposes and outcomes in a cooperative mode based on engaged relationships built on evidence produced by parties that they can be trusted. The OBC approach can be applied in diverse situations, such as communities and organisations; this model applies to regulation.

Keywords: cooperation, regulation, trust, evidence, outcomes

JEL Classification: K

Suggested Citation:

Hodges OBE, Christopher, An Introduction to Outcome Based Cooperative Regulation (OBCR) (February 1, 2022). Available at SSRN: or

Purpose, Values, Wates…

The Financial Reporting Council has issued the first in-depth assessment of the quality of reporting from private companies who have chosen to follow the Wates Principles.

The report, which was conducted with the Universities of Essex, Bristol and East Anglia – shows that the Wates Principles are the most widely adopted corporate governance code used by large private companies. And whilst there is lots to celebrate it is also sobering that the research team (Gaia, Baboukardos, Cuomo, Michelon and Soobaroyen) found that Principle One had the lowest disclosure score among the six Principles.

The good news is that we now have this data – so we can do something about it. Clarity on purpose is crucial to internal cohesion in any organisation. Learn more about how purpose plays a role across the 7 levels of Ethical Business Practice.

And help spread the word about the new Wates – so more boards both can and will take action.

100 for the Ethics Academy

The good people at The Ethics and Compliance Initiative (ECI) has announced their 2022 call for applications for the Ethics Academy Scholarship program.

In celebration of ECI’s Centennial Anniversary, the Northrop Grumman Foundation and KPMG have generously partnered to expand access to ECI’s Ethics Academy. Over the next three years ECI will select 100 qualified applicants to participate in the Ethics Academy.

The Ethics Academy was created to support a sustainable and vibrant profession by investing in the education of students interested in the ethics and compliance field and supporting the faculty members, researchers and other academics who foster the next generation of E&C practitioners.

In 2022, up to thirty-four recipients will be selected for the ECI Ethics Academy. Recipients will receive a suite of benefits and opportunities to strengthen their knowledge of the E&C industry, and network with thought leaders and experts around the globe.


The most cost effective way to ensure that ethics permeates the organisation…

I was excited to read a blog by Linn Byberg at the Institute of Business Ethics titled Ethics ambassadors: helping hands across the organisation. A worthwhile read.

Drawing on experiences of UK and international companies, this Guide:

helps organisations understand what ethics ambassadors are and how they can be used effectively in promoting an ethical culture
provides guidance on creating and motivating a network of ethics ambassadors
includes a set of practical tools for training and evaluating the efficacy of ethics ambassadors.

It is a topic close to my heart as you might know – having pioneered the concept – and authored the Institute’s Good Practice Guide on the topic. (That said, it could maybe do with a design refresh).

The content inside is 100% timeless advice though, and it is a snip at £15 via the IBE web shop.

An Ethics Ambassador programme is by far the most cost effective way to ensure that ethics permeates the organisation. Get in touch if you’d like to discuss.

18th Annual Anti-Money Laundering & Financial Crime Seminar

One for the calendar – organised by the good people at AMLP:

New Topics 2022

  • New UK Economic Crime Plan – national priorities including private sector information sharing, fraud action plan & stepping up oversight of payments and virtual currencies
  • The FCA’s supervisory priorities 2022 – commitment to a more proactive approach
  • Post-brexit economic sanctions strategies update & proliferation financing focus 
  • Companies House on the Public Register – improving the integrity and accuracy
  • Addressing the greatest challenges in 2022 – taking forward an effective compliance programme with a holistic approach to financial crime 
  • Emerging CDD/KYC & client lifecycle management strategies – driving effective processes and operational efficiency through a targeted risk-based approach, big data, digitalisation and automation
  • Building up an effective 1st and 2nd line of defence in effective risk management
  • Environmental & wildlife crime – latest highlights & expectations of the industry
  • Law enforcement on filing meaningful SARs, PPP & information sharing – combatting the new ML, fraud & financial crime threats and greater use of confiscation and asset recovery tools

View the full list of topics here.

Stellar government, regulatory & law enforcement speakers line-up

  • Carol Smit, Executive Secretary, JMLSG
  • Clive GordonHead of Financial Crime Specialist Supervision Department, FCA
  • Debbie Price, Deputy Head of Division, Proceeds of Crime, CPS & until recently Head of UKFIU, NCA
  • John Roch, Detective Superintendent, Central Specialist Crime Head of Economic Crime, Metropolitan Police 
  • Martin Swain, Director of Policy, Strategy and Planning, Companies House
  • Owen RowlandHead of the Economic Crime Unit, Home Office

View the full government and industry speakers line-up here.

Call to action: Be part of the data-driven renewal of public integrity

A call to action from our friends at the OECD:

The OECD Public Integrity Indicators establish a new benchmark for government resilience to corruption risks and provide guidance on how to strengthen public integrity. Based on primary data sources validated by governments, the Indicators will help bolster global efforts against corruption. Visit the OECD Public Integrity Indicators Portal for objective, evidence-based and actionable data.

Be part of the change – visit & use the portal

Also – I hope to see you at the 2022 OECD Global Anti-Corruption & Integrity Forum – register now, if you haven’t already. And help spread the word about this and other important #EthicsDates.

Culture > compensation = the great resignation

The Great Resignation, also sometimes called The Big Quit rolls on… and the research on the why is beginning to roll in. A lot has been said about the role of compensation (stagnant wages being eroded by inflation for example). And at this stage we probably all deserve a pay rise. Yet that won’t reverse the trend. Culture is an often overlooked ingredient – and a decisive factor.

This point is reinforced by messrs Sull, Sull,Zweig in their recent MIT Sloan Management Review article: Toxic Culture Is Driving the Great Resignation. Some quick excerpts below – that said, I encourage you to read the whole article. Especially as you reflect with your board colleagues on how to drive #EthicalBusinessPractice.

Top Predictors of Attrition During the Great Resignation

“A toxic culture is 10.4 times more likely to contribute to attrition than compensation.”

And to make it more relatable, the authors helpfully include a look at some real-life examples – and the differences are startling.

Workers are 3.8 times more likely to leave Tesla than Ford, for example, and more than twice as likely to quit JetBlue than Southwest Airlines.

And the punchline from the research should also be of interest to those working with #EthicalBusinessRegulation:

A toxic corporate culture is the single best predictor of which companies suffered from high attrition in the first six months of the Great Resignation. 

Toxic Culture Is Driving the Great Resignation by Donald Sull, Charles Sull, and Ben Zweig
Research using employee data reveals the top five predictors of attrition and four actions managers can take in the short term to reduce attrition.

Cover image:

Culture Sustainability Report Webinar

Just in from the good people at the Barrett Values Centre – for an upcoming webinar Wednesday February 9 2022:

Startling numbers

  1. 97% of CEOs believe that sustainability is important to the future business success
  2. 85% of CEOs say it’s important to run their business in a way that accounts for wider stakeholder expectations
  3. 86% of CEOs say that data about employees’ views and needs is critical, however, only 29% say that they have access to this kind of data

What to do

Webinar logo

Organizations across the world are building strategies to address the UN Sustainability Goals and ESG initiatives. Barrett Values Centre new Culture Sustainability Report offers a clear lens into how cultural values can support or hinder these ambitions and supports the actions to improve success.

Join Tom Rausch in a powerful and engaging discussion on Sustainability and Values.

Key topics:

– An overview of the Culture Sustainability Report

– Discussion of opportunities to enhance Culture Change engagements by examining Sustainability

– How Sustainability Development connects and integrates with Whole Systems Transformation


And the footnotes to those numbers in case you want to dig deeper meanwhile:

  1. Accenture Study into the UN Sustainable Development Goals (1,000 CEOs across 21 industries and 99 countries) shows that 97% believe that sustainability is important to the future success of their business.
  2. PwC 20th annual CEO Survey (2017) – 20 years inside the mind of the CEO –
  3. PwC 22nd annual CEO Survey (2019) – CEO’s curbed confidence spells caution –

Don’t do a Novak

Lots of useful examples beyond the Australian Open from Andrew Hill in the FT recently – the key point either way:

The main reason not to foster a blame culture, though, is that it makes it harder for teams to learn from their mistakes. An organisation where individuals live in fear of being outed for their errors is destined to repeat its failures, as everyone engages in what the research calls “self-image protection” at the expense of open problem-solving.

Andrew Hill in the FT Why blaming your staff publicly is always a cheap shot
Fostering a culture of culpability makes it harder for teams to learn from their mistakes

Agreed. And in case you want to dig into the difference between an Open, Just Culture vs. Blame Culture, this graphic from the book Ethical Business Practice might come in handy. Reach out if you want to talk more.

#EthicalBusinessPractice - Open Just Culture Open Just Culture
#EthicalBusinessPractice – Open Just Culture Open Just Culture

Working with Human Rights in practice

Kick start the year with EthicsTalk LIVE on the human right in practice on January 31st

The good people at Nordic Business Ethics are putting on another EthicsTalk LIVE – and it is a topic that is close to my heart.

The EthicsTalk LIVE panelists include Parul Sharma, CEO at the Academy for Human Rights in Business and Annika Ramsköld, Vice President of Vattenfall’s Corporate Sustainability. Additionally, Inter IKEA Group’s Head of Social Impact and Human Rights Gregory Priest will join together with DLA Piper’s Partner Salla Tuominen.