Governance usually works forwards. REINA® also works backwards.
Organisations have become increasingly sophisticated at defining what should happen.
That direction is necessary—but incomplete. Once a rule enters an organisation, it encounters reality: competing priorities, incomplete information, workload, hierarchy, incentives, relationships, ambiguity and consequence. The rule may remain perfectly clear. What happens next may not be. This is the territory REINA® is designed to examine.
The Gap Is Not New. The Response Is.
The OECD’s Regulatory Policy Outlook 2025 distinguishes between designing good rules and achieving their intended effects. Robust regulatory design, it concludes, must be followed by effective implementation. The OECD goes further: understanding whether regulation works requires evidence about what happens during implementation and in real life—not simply evidence that the rule was created (Organisation for Economic Co-operation and Development [OECD], 2025).
Financial regulators have reached a related conclusion inside organisations. APRA has argued that prudentially sound institutions require more than formal risk-management systems and internal controls. Leadership, culture, remuneration and accountability shape outcomes; critically, APRA describes risk culture as playing a role in whether board-approved risk appetite and policy are translated into practice (Australian Prudential Regulation Authority [APRA], 2019).
The operative word is translated.
A policy exists upstream. Behaviour appears downstream. Between them sits an organisation—and between the organisation and eventual behaviour sits a human being exercising judgement.
Formal Availability Is Not Behavioural Availability
The FCA's 2024 survey of non-financial misconduct provides an unusually large view of that problem.
The regulator surveyed 1,028 wholesale financial-services firms about incidents recorded between 2021 and 2023. 984 firms responded — 96% — representing 325,942 employees (Financial Conduct Authority [FCA], 2024).
Across the four portfolios examined, bullying and harassment accounted for 26% of reported incidents, discrimination 23%, and a further 41% were classified as other non-financial misconduct (NFM). The FCA also found material differences in how firms governed the information generated by those incidents.
The FCA cautions against treating incident numbers themselves as a proxy for culture. More reports can indicate stronger detection or a healthier speak-up environment; low numbers can mean many different things. Its data do not capture all organisational context behind those differences. That limitation is not peripheral—it is the problem. The observable outcome tells us something happened, not necessarily why.
A Channel Is Not a Voice
Organisational psychology has examined this distinction for decades.
Research on employee voice and silence shows that speaking up cannot be reduced to whether an organisation provides a formal opportunity. People make judgements about whether to raise concerns, what consequences may follow and whether speaking appears safe or worthwhile.
Morrison’s major reviews document extensive evidence on the conditions associated with voice and silence and their organisational consequences (Morrison, 2014, 2023).
Intervention research makes the lesson harder to ignore. Jones et al. (2021) reviewed 34 studies of interventions designed to increase speaking up in healthcare workplaces. Outcomes were not uniformly successful. Hierarchical and interdisciplinary relationships, organisational culture and psychological safety were among the conditions influencing implementation. The review itself cautions that much of the intervention evidence remains inconclusive.
The lesson is not that speak-up systems do not work. It is this: installing the mechanism does not determine what human beings will do with it.
A whistleblowing channel can be available. An escalation procedure can be clear. Accountability can be formally assigned. Challenge can be explicitly encouraged. And each can encounter a very different reality at the point of use. That is where formal governance becomes lived governance.
Where REINA® Begins
REINA® is our proprietary, context-sensitive experiential intervention framework, informed by scientific research and professional practice.
It begins from a deceptively simple proposition: do not examine only what the organisation expects people to do. Examine what happens when people have to do it.
That shifts the direction of enquiry.
That return path is fundamental. REINA® does not treat the participant simply as the final recipient of governance, training or leadership development. The participant becomes a source of information about the conditions in which judgement operates.
Knowing Is Not Doing
There is a behavioural distinction under this approach. People can know what good judgement requires without reliably enacting it in every context.
Webb and Sheeran’s (2006) meta-analysis examined 47 experimental tests of the relationship between changing behavioural intentions and changing behaviour. A medium-to-large change in intention produced a smaller, small-to-medium change in subsequent behaviour.
An individual's behavioural intention is not equivalent to an organisational policy, so this finding should not be used as direct evidence about governance. But the underlying distinction matters: intention and enactment are not interchangeable.
Leadership development often remains heavily weighted towards intention. REINA® asks another question:
What happens to judgement when knowing the answer is no longer the difficult part?
This is why REINA® is experiential: not to reproduce an executive's workplace, not to claim that behaviour observed in an immersion predicts future misconduct, but to create conditions in which judgement becomes observable enough to enquire into.
Observation Is Not Diagnosis
This distinction protects the integrity of the model. If a participant hesitates to challenge authority within a REINA® experience, HBA cannot conclude their organisation has a defective speak-up culture. If judgement deteriorates under ambiguity, that does not prove the participant performs poorly at work.
Experiential observation is not organisational diagnosis; it is the beginning of enquiry:
The distinction matters because sophisticated organisational work should resist two equally convenient explanations: not every failure belongs to the individual, and not every failure belongs to “the system”. REINA® is designed to keep the question open long enough to investigate it properly.
The Return Loop
REINA® moves beyond conventional leadership development. An organisation sends a leader into development. Conventionally, the hoped-for return is a better leader: more aware, more capable, more resilient, more communicative, more effective. REINA® does not reject those outcomes.
It asks whether something else can return too: information.
The movement becomes:
and then back:
This changes the purpose of the intervention. The experience is not complete when the participant understands themselves better. The enquiry returns with them.
Leadership Development as Organisational Intelligence
REINA® does not claim to have discovered that context influences behaviour. Organisational psychology already tells us that. It does not claim that experiential work can diagnose misconduct. It cannot. And it does not position behavioural science as a substitute for regulation, governance or individual accountability.
Its proposition lies somewhere more interesting. REINA® creates a structured feedback loop between human experience and organisational enquiry.
That final question changes the unit of value. The leader still learns. The organisation may learn too. And leadership development stops being only an investment in the person. It can become an additional source of intelligence about the conditions in which that person is being asked to lead.
That is the proposition HBA is testing through REINA®: what if the experience of leadership were not merely something organisations tried to improve—but something they learnt to read? Because governance normally sees what has been formalised, reported and measured. Human experience can reveal where to look next. REINA® gives that information a way back.
References
Australian Prudential Regulation Authority. (2019, November 19). Transforming governance, culture, remuneration and accountability: APRA's approach. Australian Prudential Regulation Authority.
Financial Conduct Authority. (2024, October 25). Culture and non-financial misconduct survey: Findings. Financial Conduct Authority.
Jones, A., Blake, J., Adams, M., Kelly, D., Mannion, R., & Maben, J. (2021). Interventions promoting employee “speaking-up” within healthcare workplaces: A systematic narrative review of the international literature. Health Policy, 125(3), 375–384. https://doi.org/10.1016/j.healthpol.2020.12.016
Morrison, E. W. (2014). Employee voice and silence. Annual Review of Organizational Psychology and Organizational Behavior, 1, 173–197. https://doi.org/10.1146/annurev-orgpsych-031413-091328
Morrison, E. W. (2023). Employee voice and silence: Taking stock a decade later. Annual Review of Organizational Psychology and Organizational Behavior, 10, 79–107. https://doi.org/10.1146/annurev-orgpsych-120920-054654
Organisation for Economic Co-operation and Development. (2025). OECD regulatory policy outlook 2025. OECD Publishing. https://doi.org/10.1787/56b60e39-en
Webb, T. L., & Sheeran, P. (2006). Does changing behavioral intentions engender behavior change? A meta-analysis of the experimental evidence. Psychological Bulletin, 132(2), 249–268. https://doi.org/10.1037/0033-2909.132.2.249