• Built on ownership, answerability, and consequences to drive trust and ethics.
• Starts at the board and cascades through strategy, roles, and communication.
• Reinforced by performance systems, monitoring, and fair enforcement.
• Leaders model integrity via policies, incentives, feedback, and speak-up culture.
• Measured through ethics-based performance metrics and cultural assessments.
• Sustained through adaptability and proactive risk management in changing environments.

Ahead of Risk Americas 2026 we spoke to Jennifer Marshall-Robertson. Accountability in organizations centers on ownership, answerability, and consequences, aiming to build trust through ethical leadership and transparency. It must translate into daily behaviors via governance structures, performance systems, and culture. Leadership modeling, measurement, adaptive frameworks, and proactive risk management ensure accountability remains embedded, especially amid technological and workplace changes.

How do you define accountability within your organization, and how is that definition translated into day-to-day behaviors at different levels of the business? 

First, we must establish what is at the core of Accountability.

At the core is the obligation of ownership, answerability and consequences.

The primary aim of Accountability is  the establishment of a trust- based relationship between all levels and all stakeholders of the organization which promotes responsible leadership and decision making through  ethical judgment and transparency.

Accountability must be translated into the day-to-day behaviors at all levels of the business. It must be translated from framework and  policy  to demonstrable performance actions, communication practices and consequential management. 

Accountability begins with the Board of any business/organization- as the tone is always set from the top ;and it must cascade across all stakeholder groups.

Within the business, this can be translated in some of the  following ways:

i. Clear establishment of Strategy,  Risk Appetite and Tolerance by the Board.

ii. Clear allocation of decision-making authority within the organization

iii. Transparent communication of actions and outcomes to stakeholders. ( Effective Internal and External Communications policies and practices).

iv. Effective Performance Measurement and Management Systems

v. Clear distinction between decision-making authority and oversight functions; and  segregation of duties.

vi. Continuous monitoring and reporting mechanisms

vii. Establishing a Code of Ethics and Conduct for Board and all employees, and ensuring a mechanism exists for monitoring and reporting on compliance.

viii. Defining the clear role and responsibilities of the Board and its sub-committees, with Charters developed and a mechanism for evaluation implemented.

ix. Establishing and enforcing a transparent system of equity and fairness in all practices and the treatment of issues. ( E.G Escalation, Breaches, Rewards and Sanctions, Complaints and Issue Management).

What mechanisms do you put in place to ensure leaders consistently model the conduct standards expected of their teams, especially when under commercial or operational pressure? 

Really this question asks of us: How do we ensure our leaders “walk the walk”; not “ talk the talk”, and  lead by example;  especially in circumstances where their decisions can have weighty consequences or can create an incentive driven benefit or gain to the individual?

This is a question of Culture- how do you embed and enforce  the desired culture of integrity, ethics and accountability? 

How do you ensure  an effective and consistent  culture of accountability?

Here are some  tested mechanisms that continue to work well and highly recommended:

i. Implement consistent HR policies and Conduct & Ethics  policies that apply  for all levels- no bias for Management versus rank-and-file employee. Core values and model behavior must have one common meaning for everyone.

ii. Establish Organizational Core Values that guide the Board, Management and all employees, and implement a system by which all are assessed against these established Core Values. 

iii. Reward ethical behavior and hold people accountable for unethical conduct. Unethical behavior is often caused by incentives that place too much pressure on achieving results at any cost. Performance evaluation, Rewards and Incentives must not only be driven by financial and other typical corporate targets but also be informed by evaluation of ethical decision making and core elements of the organization’s core values and code of conduct.

iv. Implement feedback mechanisms for leadership- e.g 360 Feedback and other employee survey feedback mechanisms.

v. Implement a safe space for honest feedback by employees/ “speak up” culture , without fear of repudiation or punishment. ( E.g Clear Non-Retaliation Policies, Anonymous feedback channels).

vi. Implement clear policies and consistent practices on Discipline violations, irrespective of rank and title.

vii. Implement Integrity and Ethics audits as part of the Audit work program- Board should seek assurance on risk taking areas of the business, areas of approval authority and areas that could be considered integrity “hotspots”.

How do you actually measure whether your conduct culture is genuinely embedded, rather than simply documented through policies and training programs? 

There are several ways to gauge conduct culture, however the following two key mechanisms have been found to be very effective and consistent with best practice recommendations:

i. Integrate Ethics into Performance and Incentives - Evaluate employees not only on what they achieved (sales, targets) but how they achieved it;  and incorporate performance metrics that assess Behavioural Attributes in relation to the organization’s core values and Code of Conduct & Ethics. 

ii. Cultural Assessments- E.g (a) Anonymous Surveys of  employees on their perceptions of fairness and trust within the organization; (b) Formal employee feedback mechanisms; (c) 360 feedback; (d) Audits (e)External stakeholder survey/feedback (e.g customers, shareholders).

What are the best ways to ensure frameworks can evolve to remain effective as the organization grows, restructures, or adopts new ways of working?  

The key is designing frameworks for adaptability and resiliency and not based on rigid rules or controls; and most importantly with strategic alignment and clarity on the organization’s vision and objectives.

Key principles:

i. Design frameworks that decentralize decision making, allowing for reduction of silos and execution by cross functional teams.

ii. Implement a culture of continuous learning, innovation and openness to adjust and change as a part of normal routine. Build a responsive and agile  organization.

iii. Implement effective change management procedures, which promote active employee engagement and involvement in the process.

iv. Data driven and technology enabled.( Technology must be seen an essential enabler and integrated in all aspects of the business).

v. Build redundancy across the organization.

vi. Scalability and sustainability 

What steps should organizations be taking to proactively identify and address emerging conduct risks - such as those driven by technology, remote work, or changing workforce expectations - before they impact culture?  

Conduct risk is an aspect of operational Risk – it is the risk that a firm's behavior, products, or services lead to poor outcomes, detriment, or harm for customers, stakeholders, or the integrity of financial markets.

Emerging risks are those risks that are characterized by their newness, insufficient data, and a lack of verifiable information and knowledge needed for decision-making related to them.

To  proactively identify emerging conduct risks in the current operating environment, it is essential that organizations establish context and first  seek to understand how  technology and AI proliferation, remote work and changing workforce expectations  are influencing the current day and future workforce and operating environment of their organization and more so conduct risk.  

What is the organization’s Technology Transformation Strategy and Remote Work Strategy? Are these defined and clear frameworks existing? 

Have scenarios been established on how the key conduct risks of mis-selling, conflicts of interest, poor product design and compliance failures could arise?

The same principles applied for effective Governance and Risk Management must be employed in these scenarios, starting with a clearly defined Strategy and an understanding of the various inherent risks and the sources of risk attached to AI transformation, increased use of technology in daily customer interfacing, products, services  and in remote work.

One of the key pitfalls of proactive risk identification is lack of required knowledge, skills and the governance and risk requirements for these growing new areas of business operations.

Prevalent trends:

i. Invasive AI Surveillance and Privacy Erosion

a. Biometric Surveillance: Companies are deploying AI-powered webcam surveillance that tracks employee attention, disengagement, and even facial expressions to judge productivity, raising significant ethical issues about privacy in the home.

b. "Shadow AI" Usage: Use of  unauthorized Generative AI tools (Shadow AI) on personal accounts to manage work tasks, which can accidentally leak proprietary organization data 

ii. Gamification of Productivity Metrics:  Employee dishonesty about actual time spent on work activities while working remotely by the use of tools such as "mouse jigglers" to  fake activity, leading to false performance reporting, measurement and reward.

iii. Erosion of accountability- potential for blame to passed unto Agentic AI developers or employees blaming technology for errors or misappropriate business practices or decisions, especially where organization utilizes AI in the decision making process or in the delivery of products and services to clients.

iv. Data integrity and security risks