BEAR implementation needs to be human-led

Superannuation funds have an opportunity to implement genuine cultural change by implementing the Banking Executive Accountability Regime (BEAR) Deloitte believes.

As the Australian Prudential Regulation Authority (APRA) told super funds to prepare for the BEAR regime, which currently only applies to big banks, the Australian Institute of Superannuation Trustees (AIST) said there was no harm in super funds getting their houses in order while they waited for legislation.

Deloitte partner for governance, regulation, and conduct advisory, Rosalyn Teskey, told AIST: “We expect most of the regime that applies to banks will be replicated for super trustees, so there are a lot of ‘no regrets’ activities”.

“BEAR provides the opportunity to implement genuine cultural change. To do that, it shouldn’t be seen as a compliance project. It needs to be a human-led project,” she said.

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“This means it is important to engage the likely accountable persons and their respective support teams early and engage the right stakeholders so accountable persons feel supported through this process.”

Teskey said the implementation needed to be done with clear communication across the business to facilitate transparency and inclusiveness.

“The likely accountable persons need to feel that BEAR implementation is for them – and not being done to them,” Teskey said.

Commenting on the Big Four’s implementation, Teskey said it while it was straightforward to define 80% to 90% of the accountabilities of executives, the outstanding 10% to 20% required hard work and potentially difficult conversations to identify exactly what they were and how it would play out in real life.

Another challenge was to ensure the accountability maps and statements were up to date.

“This isn’t made easy with organisations being required to notify APRA within 14 days about every change at the level below the senior executives caught by the regime,” Teskey said.

“Further, some organisations have struggled with identifying and assessing where there might be a breach of the BEAR requirements. It’s easy to plan for in theory but harder to actually apply that in day-to-day scenarios.”