In 2016, the Financial Reporting Council asked a question that should have been rhetorical: if the evidence connecting culture to long-term performance is this strong, why isn't every CEO treating it as a boardroom priority?

Its Corporate Culture and the Role of Boards report set out three things boards needed to get right: connect purpose to strategy, align values with incentives, and actually measure the culture.

Five years later, we went back into the room ourselves.

What we actually found

In 2021, we worked directly with the FRC on Creating Positive Culture: Opportunities and Challenges. Across 13 roundtables, 134 engaged organisations and 140 professionals, we personally conducted 24 confidential interviews with company Chairs, CEOs and Non-Executive Directors.

The headline finding wasn't comforting for anyone hoping the 2016 report had already done its job: most of its seven original findings were simply reaffirmed. The importance placed on culture had grown. The same gaps had not closed.

Board involvement had improved on paper. The 2018 UK Corporate Governance Code now expects directors to ensure culture promotes integrity and openness, and section 172 reporting requires companies to explain how they've engaged stakeholders. But our interviews found real board involvement still varies wildly — from genuinely shaping culture, to questioning it once or twice a year and moving on.

Assurance told the same story. When the Chartered Institute of Internal Auditors polled 40 organisations for our research, 82% said they carry out some form of culture audit. Yet 68% of boards and audit committees don't proactively ask internal audit to report on culture at all. The work is happening. It's just not reliably reaching the board table.

Middle managers, meanwhile, were still where culture actually lives or dies — not the boardroom, not the shop floor. As one former chair told us during the research: 

"What usually makes or breaks a culture is not the top or bottom, it's the middle."

So, is this still relevant?

More than it was in 2021. However, three things have shifted since:

Trust has moved. 

Edelman's 2024 Trust Barometer found trust in business now exceeds trust in government and media. When people trust businesses more than the institutions meant to govern them, culture stops being a private HR matter. It becomes public accountability.

Leaders are less certain of their own survival. 

PwC's 27th Annual Global CEO Survey in 2024 found approximately 45% of CEOs believe their company won't be viable in 10 years on its current path. That's not a workforce engagement problem. That's a board-level survival question, and culture sits inside it.

Fulfilment, not just engagement, now predicts who stays. 

OC Tanner's 2023 Global Culture Report found personal fulfilment had a more decisive impact on retention and advocacy than any other factor measured. We also found this in our 2023 Cracking the Culture Code study. That's further than the 2016 report was even asking boards to look.

The gap hasn't closed. It's just better understood.

Our own conclusion in 2021 was blunt: the issues raised in the 2016 report were still relevant, five years on. Reporting had improved. Understanding had improved. But reliance on staff surveys and ad-hoc site visits to gauge culture remained, in the report's own words, "a concern."

As our Managing Director, Niall Cluley, put it at the time: 

"Organisations have progressed significantly with the framing of culture... It is also great to see that of equal importance is the recognition that measuring, embedding, and evolving culture is a never-ending process."

That's still true today. The question for boards in 2026 isn't whether culture matters — most now agree it does. It's whether they have a way to measure it that they trust as much as they trust a P&L.

That's the gap we still work in. If you want a research-based way to answer that question at board level, get in touch.

Sources

• FRC, Corporate Culture and the Role of Boards: Report of Observations, 2016 (https://www.frc.org.uk/library/standards-codes-policy/corporate-governance/corporate-culture/) 
• FRC, Creating Positive Culture: Opportunities and Challenges, December 2021 (https://www.frc.org.uk/library/standards-codes-policy/corporate-governance/corporate-culture/)
• PwC, 27th Annual Global CEO Survey, 2024 (https://www.pwc.com/gx/en/ceo-survey/2024/download/27th-ceo-survey.pdf) 
• Edelman, 2024 Trust Barometer (https://www.edelman.com/trust/2024/trust-barometer) 
• OC Tanner, Finding Fulfilment: 2023 Global Culture Report  (https://www.octanner.com/en-gb/global-culture-report/2023-finding-fulfillment)