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Follow dinamedland on Twitter       A blog around the issues facing the boardroom...in the UK and around the world. I aim to reflect a wide-ranging set of views and kindle ongoing and much-needed debate. The aim is for more 'board talk' and less 'bored talk'.  

July 28, 2013

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The Irony In The UK Govt's Call For Inclusion By UK plc

Posted on March 29, 2017 at 8:20 PM

There are three options, as I see it, regarding a judgement on the timing of the UK government's call on FTSE 350 CEOs to get serious about inclusion - that very politically correct word added on to 'diversity'.'Inclusion' means race, ethnicity, people of colour, actually representing the reality of Britain on the streets in its boardrooms.

(If this blog seems fiesty, let's say it might be re-channeled energy: Article 50 was triggered today, to take Britain out of the EU and no, I am unapologetically not a fan of that. We don't know what the Brexit baby will look like yet - and I wrote about this on Forbes this week.I have also written about Britain, race and boardrooms many times- both here and on Forbes and the search engines work).

Let's start by giving Prime MInister Theresa May's government the benefit of the doubt, on timing. The announcement from the Department for Business, Energy and Industrial Strategy in the link above was made yesterday, presumably to make sure it happened before today, when (obviously) no journalist would be interested.

It could also be that BEIS needs help with its comms team, and timings. But I suspect we are going to see a lot more of this sort of timing, where things that matter - due to bad scheduling and overworked resources - get overlooked, for the most part as it's all hands on deck for Brexit and the de-tanglement from the EU and EU law.

The third interpretation, of course, is 'unconscious bias.' As someone who has followed - and helped publicise - government attempts to increase diversity in UK plc for years, I find they bizarrely often occur at times when they are not likely to get a lot of traction. It does make one question the levels of commitment, just a little.

Some of the media does well in raising such issues. The Guardian had a story on the first female black footballer - a case of mistaken identity. To quote from the Guardian story (emphasis is mine):

"For Sabrina Mahfouz, who co-wrote the production with the poet Hollie McNish, the very fact that such an important pioneer could be forgotten, and mistaken, says everything about the under-representation of women, and in particular women of colour.

“I also think it is really important to constantly remind people that there was immigration to this country from thousands of years ago, and that those people had always been involved in the things that are now known as ‘British’."

I shared it to my Facebook business page @DinaMedlandWordsThatWork - where people are engaged and do get excited....with little traction. I have found the same thing to be true of every single post I have written about racial inclusion.....but write about high heels, and you can suddenly hit the mega number of eyeballs, it seems.

I wonder if people just read the things to which they connect, anyway.

Or...a more sinister prospect ? Is there an algorithm that downplays race ?

Nah. It's just post-Brexit exhaustion, surely, on my part to consider such a thing. But it's one to think about - especially if you care about changing the face of British business.

UK Business Minister Margot James has now written to the chief executives of all FTSE 350 companies urging them to improve diversity and inclusion in the workplace, says the press release.

In her letter, she called on the UK’s largest companies to take up key recommendations from the Baroness Ruby McGregor-Smith Review into black and ethnic minority progression in the workplace, including:

publishing a breakdown of their workforce by race and pay

setting aspirational targets

nominating a board member to deliver on those targets

How high do you think this will be on the agenda of any FTSE 350 plc boardroom  today?

Having watched my evening news like many of you, I am well aware of the immigration concerns of many who are delighted that today the 'Leave' vote in the referendum was respected. But if this government now focuses on the white working class voters who were largely behind that vote - and somehow this inclusion strategy gets derailed, it is a recipe for disaster - and not an issue on which to play politics.

Thoughts on a postcard, please or tweet at me @dinamedland.

PS This blog is in talks about sponsorship with a number of firms, and while I thank them for being interested, it may be more than they bargained for. It does not happen often. But you have to believe in my right to independent editorial comment, always with the best of intentions on governance and ethics. Thank you for reading.

Paying The Price On Reputation - More On #PwC

Posted on March 10, 2017 at 11:30 AM

When something goes wrong for a business - particularly a large one - it's often very easy to blame one or two individuals. Even that doesn't happen often, for those at the very top.

We still struggle with true accountability, and there are multiple places to hide. But all the talk about 'trust' and corporate governance since the financial crisis should continue to make businesses focus harder on public opinion - and reputation. It might also make them reconsider how they choose to promote themselves.

Too much glitzy self-promotion for an auditing business was probably never a great idea - although it did provide lucrative work for over 80 years in the case of PwC and The Oscars. See my post on Forbes: 'At Last, Corporate Governance On The Red Carpet At The Oscars.'

PwC is not having a good year so far on many levels.

Childish, perhaps - but I am hoping those formidably funny women Jennifer Saunders and Joanna Lumley will do a comedy skit around high heels soon to keep this story on Forbes going - because it's more important than it might seem, to connect 'real people' with the workplace.

Now a survey by Morning Consult,  a research and brand monitoring platform that tracks over 500 of the largest public-facing brands in the country on a daily basis, finds that PwC's  ill-fated involvement with the Oscars has hit its brand.

According to the survey, the day before the Oscars, 11% of people said they had an unfavorable view of PwC. By March 7, that number jumped 6 percentage points, to 17%.

And for many, it says, the Oscars were an introduction to PwC: During that same time period, the number of Americans who said they never heard of PwC decreased 4 percentage points, from 39% to 35 %.

So much for glitzy affiliaton.

And as this site powered by WEBS is being completely useless (again) with uploading images - for now you will have to go here for the graph, which is worth noting.

Note: re blog sponsorship, I am open to posting this blog on a sponsor's site, given the right sponsor. #ITfatigue

Oscars, Audit Firms, Accuracy And Inclusion

Posted on February 27, 2017 at 11:00 AM

Oscars, audit firms, accuracy AND inclusion: all in one place? Really. You might well wonder.

Perhaps it's just me - I tend not to think of issues in boxes -but in an inter-connected way - because that is how the world actually works. So when it rapidly emerged on Twitter that the accountancy firm PwC was responsible for the error at #Oscars2017, the first thing I thought was: "but it's an AUDIT firm - it's meant to be accurate."

Silly me. On the other hand, while I watched the BBC Breakfast News in disbelief, the dismissals were already starting.

In case you were wondering, I have no vendetta against PwC.They do some excellent work in corporate governance, for example. But I did write something on Forbes on January 25 which unfortunately involved their London offices - and has I see now had 227,130 hits.....it went up very very fast and is still rising.( No, I don't get paid any more now for more hits.)

At the time PwC was keen to stress it wasn't them, it was their recruitment firm that had the dress code policy. To which I responded here, on Board Talk.

Do big accountancy firms - like large banks - hide behind their very size? Do they know what is going on in every bit of the organisation ? Surely they should.

If I was Warren Beatty - who read out the incorrect reward - I would be very angry. Because millions of people who never bother to read the detail will walk away thinking 'poor guy, he had a 'senior moment.' No, he did not. Speaking for myself, I felt for him deeply as I watched him try to make sense of what had happened - while the world went viral with information and mis-information.

PwC made an appalling error. Will the accounting regulator the Financial Reporting Council (FRC) say anything ? PwC is already being investigated for its audit of Redcentric.

Let's see. You could argue that this is not an accounting matter. But it is a matter of reputation. And the general public is pretty cynical, when it comes to the power of the big accountancy firms. It's all about trust - right ?

Note: ain't social media grand ? Here's some input from a follower...    meet the PwC partners involved in the #Oscars2017 'winnning envelope fiasco'

It's All About You: #ESG Risks In #Pension Schemes

Posted on February 21, 2017 at 8:05 AM

It was only a matter of time before Environmental, Social and Governance (ESG) risks were recognised as being personal. Volkswagen opened that door in a different way, for consumers. Now the focus is on pensions.


The Pensions and Lifetime Savings Association (PLSA) has today released its newly commissioned study into the environmental, social and governance (ESG) risks facing members of default funds offered by defined contribution (DC) pension schemes in the UK.


The number of savers enrolled in DC workplace schemes in the UK is expected to rise to 17 million (up from 11 m today) with an expected aggregate pension pot of £554bn (potentially as high as £914bn) by 2030; and currently 90% cent of DC savers are in their scheme’s default fund, it says.

At the same time, ESG investing has gained significant momentum in the UK, with £1.4tn in assets under management in the wider investment community in 2015 versus £500bn in 2013. "The combination of these two factors underscores the importance of managing ESG risk in default fund arrangements" says the PLSA.


The research has been done by Sustainalytics, a global provider of ESG and corporate governance research and ratings. It assessed the equities allocation for a typical DC default fund, and mapped this against the most prominent ESG risks. Key findings include:


First, and importantly - ‘human capital’ is the single biggest source of ESG risk at the companies in which DC default funds invest, accounting for 11% of the ESG risk to which default funds are exposed. (my emphasis)

Climate change risks from energy use and greenhouse gas emissions are also substantial, affecting 22 industries found in a typical DC default fund’s portfolio, more than any other ESG issue.


“Pension funds are moving beyond the debate about whether or not the environmental and social impact of their investments matters to long-term returns and on to what they should do to manage it" said Luke Hildyard, Policy Lead: Stewardship and Corporate Governance at the PLSA.

What can one say ? Thank goodness for that.

Or as the author of the report  Doug Morrow at Sustainalytics said:


“Given the convergence of UK market trends, understanding and managing ESG risks in DC default funds is becoming increasingly important. Our research findings reveal pension schemes can potentially mitigate these risks by embedding ESG investment products in default fund allocations and engaging on ESG issues with external managers and investee companies. We applaud the PLSA for raising awareness of this critical topic and believe these findings will help to advance the dialogue around ESG issues and default funds.” (my emphasis).

Is Integrated Reporting Becoming Mainstream ?

Posted on February 15, 2017 at 3:05 PM

The short answer to the question is - not yet - but it is certainly catching on around the world as a business choice for better demonstration of value creation. Regulation is being seen as a key driver of progress, and South Africa, the UK and Europe are leading the way in adopting the concept.

In the last few years, following increasing coverage of integrated reporting (IR) - including by me here on Forbes in late 2013: 'If I Had More Time I Would Have Written A Shorter Letter: Integrated Reporting'   (19,100 views as of now) - there has been much more discussion, both in public forums and in private meetings about its worth. Today a snapshot taken of 50 organisations from around the world who have embraced IR finds that 88% of them explain their commitment as being in terms of value creation.

There are big names on this list, including Aegon, AstraZeneca, Eni, Fujitsu, Takeda, CLP, National Australia Bank and Marks & Spencer. The stakeholder communications company Black Sun, which compiled the research, finds that while there is no uniform approach in the way in which businesses are adopting IR, "there is no doubt that integrated reporting is having an impact and becoming the iinternational best practice approach."

It is gathering pace rapidly in Asia/Oceania and Japan, says its report just out. It finds that organisations are using the IR framework to provide their stakeholders "with a more complete and longer-term perspective on strategy, performance and value creation."

A clearer purpose, moving beyond just financial value, recognition of the importance of stakeholder relationships, an increased focus on materiality and connectivity of information were just some of the reccurring themes, says the research. Its key findings include:

– 90% of organisations clearly identify stakeholders

– 76% of organisations clearly identify material issues

– 94% of organisations link resources and relationships with either the business model or strategy


Last month The International Federation of Accountants (IFAC) released a paper stating that "Integrated Reporting is the way to achieve a more coherent corporate reporting system, fulfilling the need for a single report that provides a fuller picture of organisation’s ability to create value over time." (my emphasis)

At the end of last year, the joint International Integrated Reporting Council (IIRC)  and International Corporate Governance Network (ICGN) conference in London encouraged the adoption of integrated reporting as information architecture that helps to underpin investor stewardship and good corporate governance.

Black Sun's own recent survey, conducted alongside AICPA, CIMA and the IIRC found "widespread desire among C-suite executives to deliver purpose beyond profit (89%), as well as acknowledging of the benefits of integrated reporting and integrated thinking."

Changes in corporate reporting should be seen as part of business innovation. At a time when climate risk is high on the agenda for businesses and investors, integrated reporting becomes an even more compelling proposition.

And 'purpose beyond profit' may well be a budding theme of 2017. Certainly, if the younger generation is to be considered for its views, it wil be. Later this month I am delighted to attend again the Doing Good, Doing Well conference organised by the MBA students at IESE Business School, in Barcelona.

It dates back to 2001 when a group of students in the Responsible Business Club at IESE wanted to go beyond the classroom and beyond the case studies by inviting leading professionals and thought leaders to campus to engage with students. Now it has become an annual tradition and they say it is the largest student-run conference in Europe.

Purpose beyond profit' is its mantra - and among other things, we will be talking about 'Shared Value.' Stay tuned.

To request a copy of the Black Sun research please contact Sarah Myles at [email protected]



HSBC Faces Consumer Anger On Palm Oil Financing

Posted on February 13, 2017 at 12:00 PM

HSBC, Europe’s biggest bank, is facing "a consumer backlash" from their customers over their ongoing financing of palm oil companies destroying Indonesia’s rainforest, according to latest information compiled by Greenpeace and YouGov.

A few weeks ago Greenpeace published a report called 'Dirty Bankers' - it said that despite having policies which they claim ‘prohibit the funding of deforestation’, HSBC had been financing some of the most destructive palm oil producers in Indonesia, responsible for destroying scarce orangutan habitat, labour abuses, and increasing fire risk through rainforest clearance and illegal drainage.

Since then, 120,000 people in the UK have signed its petition calling on HSBC to stop financing deforestation. They include 30,000 HSBC customers, says Greenpeace.

In a statement it says: "Due to the unusually long-term, stable relationship between banks and their customers, Greenpeace decided to ask petition signatories whether they were HSBC customers or not, and 25% of the UK signatories have affirmed that they are."

Greenpeace also commissioned YouGov to poll UK adults on their attitudes to controversial lending practices by banks. 75% of those with their main bank account with HSBC said they would be concerned if their bank was ‘financially supporting companies who cut down trees in rainforest to assist palm oil production’, and 50% with their main bank account with HSBC said they would consider moving their account.


“When we launched this campaign, we were worried that people might be uncomfortable with getting involved if it was their bank lending money to companies that destroy rainforests. But it turns out that the opposite is true. People are particularly motivated when it’s their own bank doing the wrong thing. They want get stuck in, and thousands of customers have sent a clear message to HSBC that they need to clean up their act." said Jamie Woolley, Forest Campaigner for Greenpeace UK.

It is not just that ESG concerns are increasingly becoming commonplace - and taken as a 'given' for a younger generation. For some of my writing on that, see my page on Forbes - or just Google 'Dina Medland ESG Forbes.'

But the palm oil trade is clearly also an issue involving climate risk. Climate Related Financial Disclosure For Business: An Imperative For 2017 I wrote at the start of the year.

The Task Force on Climate Related Financial Disclsoure has just ended its public consultation : watch this space.

Hermes Calls For #CorpGov Code For Private Infrastructure Assets

Posted on February 13, 2017 at 11:10 AM

Hermes Investment Management is calling for an enhanced corporate governance code for private infrastructure assets.

It suggests the code "would provide essential social services to help close the governance gap and ensure consistent and optimal outcomes for investors, employees and other stakeholders."

In its paper ‘Corporate Governance of Public Service Infrastructure Assets’,  Hermes outlines two key areas for consideration which it says are designed "to help close the governance gap created by the lack of existing relevant and/or appropriate reference points for these businesses."

They include recommendations for boards. In contrast to publicly listed companies, it says the boards of directors for private infrastructure investments "are often made up principally or wholly of representatives of one or more of the shareholders. This can result in large – and arguably unmanageable – boards, conflicts of interest for board members and lack of sufficient board diversity."

It is suggesting an "enhanced corporate governance framework" which could include:

o Initial and periodic documented board effectiveness reviews whereby businesses periodically and genuinely consider the Board’s skills and diversity, the quality of debate and decision making, the adequacy of conflict management processes, and its overall effectiveness in a structured and documented manner to help ensure risks and opportunities are optimally managed.


o Independent Chair to help provide valuable assistance in steering robust and effective board debate and stewarding interactions between shareholders, the Board, sub-committees and management.


o A minimum number of independent directors as the presence of independent, experienced industry professionals can provide comfort for investors, end users and other stakeholders.


There is "increasingly robust evidence of the relationship between well-governed companies and higher long-term returns. Short-termism and a lack of focus on ESG issues can erode long-term shareholder value. An enhanced governance toolkit for infrastructure businesses, which ensures the interests of stakeholders feature appropriately in the minds of directors would be therefore be valuable" says Hermes. And it sets out areas for consideration.


“Few asset classes are as necessary, or significant, to the daily lives of individuals as infrastructure. These businesses, which can provide essential social services, including access to water, energy, health and social care, and vital transport services, are the basic physical and organisational structures and facilities needed for the operation of a society. However, ownership of these assets continues to transfer from the public to the private sector. While the listed company corporate governance guidelines are helpful, some of the principles may not be appropriate (nor accepted) in a more bespoke private market environment. The result, therefore, may not always be a consistent, or optimal, outcome for investors, employees and other stakeholders” said Peter Hofbauer, Head of Infrastructure, Hermes Investment Management. (my emphasis)


"Regarding the wider consultation that the Government is carrying out, we believe the time is right for the authorities and the infrastructure industry to consider implementing some or all of the options set out in our paper. There is a distinct need for initiatives that will deliver an enhanced governance framework for the benefit of infrastructure company boards, shareholders, stakeholders, the public interest, and increase accountability" he added.


It's a compelling argument.

In their excellent and thought-provoking book The Public Wealth of Nationshttps://www.amazon.co.uk/Public-Wealth-Nations-Management-Economic/dp/1137519843" target="_blank"> Dag Detter and Stefan Folster argue that better management could increase the annual return on state assets by $2.7 trillion—more than current global spending on infrastructure.

Spare a Thought For CPOs Amid Global Risk And Digital Challenge

Posted on February 9, 2017 at 11:20 AM

Cost reduction and managing risk unsurprisingly top the list of procurement leaders’ business priorities in 2017, according to Deloitte’s annual global Chief Procurement Officer (CPO) survey, just out.

The number one priority for 79% of CPOs is reducing costs. Over half (57%) are worried about managing risk - particularly true of those who are based in the United Kingdom, with uncertainty around Brexit and outcomes from upcoming trade negotiations.

Other key global risks cited include weakness and volatility in emerging markets; rising geopolitical risk; the possibility of a renewed Euro crisis and spill over effects of any slowdown from China.

In addition, 54%  of global respondents report a resurfacing of procurement risk, which could include price volatility, disruptions in supply and supplier bankruptcy. This is up from 42%  in 2014.

 “Like other business leaders managing a global backdrop of economic and political risks, CPOs continue to focus on cost and risk management in 2017 to support growth in an uncertain market. So far, this is proving successful for CPOs, with 58% achieving better savings performance than last year. However challenges with talent and poor adoption of digital technology still hinder progress. Unless addressed quickly, these could jeopardise the future of procurement” said Lance Younger, Deloitte UK head of sourcing & procurement.

Indeed. And the findings are depressingly familiar when it comes to digital transformation.

Source: Deloitte Global CPO Survey 2017

“We continue to see procurement functions shrink in size, whilst the breadth of responsibilities and expectations continue to increase. Companies are demanding greater productivity, but overworked employees are not the solution. Instead, new, sustainable operating models are required. One approach is to empower talent by embracing digital and innovative technologies – such as automation, cognitive procurement and analytics – at a much greater scale” said Mr Younger.


This year's global survey reveals that 75%  of CPOs believe that procurement’s role in delivering digital strategy will increase in the future.


They report that the impact of automation and robotics on their function will steadily increase from 50% to 88% in five years’ time, and 93% by 2025.

Source: Deloitte Global CPO Survey 2017


Some 65% see analytics as the technology area that will have the most impact on the function in the next two years, but many see the quality of data available as a significant barrier to adoption. However an issue with talent is apparent, with 62% claiming that there is still a "large to moderate skills gap" across analytical abilities.


“As the rapid speed of technological change continues to sweep over businesses globally, procurement is at a tipping point and must take advantage of high levels of executive support. Digital will amplify great talent and strong CPOs must align the digital transformation of the function with ongoing business priorities” said Mr Younger.

Like I said, spare a thought for the CPO.


Conducted in association with Odgers Berndtson, the Deloitte  global CPO survey is an annual survey of chief procurement officer’s across the world. 480 procurement leaders from 36 countries around the world took part in this year’s survey, representing organisations with a combined annual turnover of $US4.9 trillion.


Specific UK statistics are based on 79 respondents with combined annual turnovers of £677 billion.

Investors: Key Agents For Change In Business Practices On Animal Welfare

Posted on February 2, 2017 at 12:35 PM

Spare a thought for business. In a world where guessing what's next on the agenda from those in political leadership becomes a major daily past-time, it must be hard to stay focused on what the consumer public's concerns are - and keep up with them, or be seen to do so.

Starbucks was very quick to say it would hire refugees, as international public outrage became ever more vocal around U.S. President Donald Trumps actions.

Since then, Amazon, Apple, Facebook, Google, Uber (all technology firms inspired by and reliant on immigration) have spoken out - as have those in other sectors. But there are also other public concerns that often don't make the headlines but are nevertheless very real for consumers.

Animal welfare is one of them. So it's worth noting that in the grim last days of January, the global Business Benchmark on Farm Animal Welfare (BBFAW) report was published. Now in its fifth year, the BBFAW provides an annual review of how 99 of the world’s leading food companies are managing risks and opportunities associated with farm animal welfare.

Starbucks - along with Domino's Pizza Group plc and Restaurant Brands International-  is near the bottom of these rankings.


On the other hand, 13 companies occupy leadership positions in the Benchmark’s top two tiers. "These companies demonstrate strong commitments to farm animal welfare and have established management systems and processes" says the report. They include Coop Group (Switzerland), Cranswick, Marks & Spencer, Migros, Noble Foods and Waitrose in Tier 1, and BRF, Cargill, Co-op (UK), Greggs, McDonald’s, Tesco and Unilever in Tier 2.

The report was compiled in collaboration with investment firm Coller Capital and leading animal welfare organisations Compassion in World Farming and World Animal Protection.

The good news is that investor pressure works - 73% of companies have now published farm welfare policies , compared to just 46% in 2012. And 65% of companies have set and published targets on animal welfare, compared to just 26% in 2012. That's a fairly rapid rate of progress.

 "Currently, 13 companies occupy leadership positions in the Benchmark’s top two tiers. These companies demonstrate strong commitments to farm animal welfare and have established management systems and processes. They include Coop Group (Switzerland), Cranswick, Marks & Spencer, Migros, Noble Foods and Waitrose in Tier 1, and BRF, Cargill, Co-op (UK), Greggs, McDonald’s, Tesco and Unilever in Tier 2" says the report (my emphasis).

“With 26 companies moving up at least one tier since 2015, there is a clear indication that the food industry is finally starting to treat farm animal welfare as an important business issue” said Nicky Amos, BBFAW Executive Director.

“From farms to fast food chains, global investors want well managed, forward-thinking food companies. The Benchmark is an essential tool to help investors find such corporate leaders, as a company’s disclosure of farm animal welfare practices offers a valuable insight into the wider quality of corporate management" said Jeremy Coller, Founder of Coller Capital and the FAIRR (Farm Animal Investment Risk & Return) Initiative.

“It’s very encouraging that 26 companies have risen up the Benchmark this year. That suggests a critical mass is building in the food sector to improve farm animal welfare management practices. The market is changing rapidly with consumers demanding higher welfare standards, regulators introducing tougher laws in areas such as antibiotic use, and investors driving change through new initiatives like FAIRR” he added.

(The Benchmark is the first global measure of farm animal welfare management, policy commitment and disclosure in food companies and is designed for use by investors, companies, NGOs and other stakeholders interested in understanding the relative performance of food companies in this area. More information on the programme can be found here).

On High Heels And Corporate Professionalism

Posted on January 27, 2017 at 11:40 AM

Yes, if you put 'high heels' in a headline in 2017, you are likely to draw more hits than if you put in 'inequality.' Call it the times we live in.

This post three days ago by me on Forbes High Heels And Workplace Dress Codes: Urgent Action Needed, Say UK MPs  has had - well, you can just about see here (at time of writing now) 205,705 views. The headline was edited to remove the quotes: it is actually the title of the report - rather than me being clever with headlines.

I would like to believe the content is also the reason it is whizzing around. But I don't think PwC is very pleased, although the clarification is there in parentheses: "Nicola Thorp had a job as a receptionist at PwC, one of the Big Four accountancy firms, when she was sent home in December 2015 without pay, for not wearing heels. (Her employer was not PwC itself but Portico, a personnel firm, which maintained the dress code in question.)

So how does it work then, this ducking by big firms behind their outsourced employers ? It didn't do Sports Direct much good. 

This may seem a frivolous comparison, to lump 'dress code' with 'Victorian working practices', but I don't think it is. It's all about accountablilty - throughout the supply chain, and ending all the way at the top, with specific individuals..

Elevate it to another level, and you have the excellent argument made by John Kay (which should be made by far more people and heard far more often) : Personal liability is the means of deterring repeat offences of corporate crime.

It's all about liability, which presumes making it your business to know how your business is being run.

Instead, large businesses - and large professional firms in particular-  often act in siloes around the organisation, leaving hapless PRs and corporate communication departments to try and mop up any damage when some of their working practices hit the public eye.

The UK government report says: "The dress code which gave rise to this petition had been in place for eight or nine years. Portico had not taken advice about the legality of this dress code, either on its introduction or when it last reviewed the dress code in 2014. Questioned about the rationale for the strict dress code, Simon Pratt (Managing Director of Portico) explained that "the market, and the industry itself, has driven to standards to date."(my emphasis)

Ah yes - with all its talk about the importance of diversity, did senior people at PwC ever look at their receptionists and wonder why they all looked so similar in appearance ? Some professional consultancies go out of their way to achieve that - isn't it called 'branding' ? Disconnects everywhere....and watch this space for more on that subject later.

I leave you with two thoughts to continue this debate beyond the 'such dress codes are sexist' argument.

Earlier this week The International Bar Association (IBA) launched a global investigation into the reasons why so many women lawyers leave law firms, and on occasion the legal profession entirely. Its Legal Policy & Research Unit (LPRU) says it "seeks to secure information on the professional barriers experienced by women in the legal profession."

'Women leaving law firms to the degree at which they are presently doing is very worrying. This specific issue lies within the broader serious problem of a major lack of diversity in the legal profession, particularly within senior roles" said Isabel Bueno, Chair of the IBA Women Lawyers' Interest Group.

Before you scoff - I am not saying the professional barriers are high heels. But I think all professional firms would do well to take  a good, long hard look at their culture, particularly amid generational change.

When you look at the research done by the Social Mobility Commission in its report just out (also covered by me yesterday on Forbes), it's worth noting that "access to Britain’s professions remain dominated by those from more privileged backgrounds."

"But even when people from working class backgrounds manage to break into a professional career they face an earnings penalty compared to colleagues who come from better-off backgrounds...women and ethnic minorities face a 'double' disadvantage in earnings'" says the report.

'Privilege' is defined as having special rights and advantages. But being seen as 'privileged' is also all about perception, and that involves how you speak, and also how you choose to dress.

There's no denying it. "This unprecedented research provides powerful new evidence that Britain remains a deeply elitist society" said the Rt Hon Alan Milburn, chair of the Social Mobiility Commission, on the launch of this report.

Action on that includes businesses looking hard at their recruitment and advancement policies. If they also take the time to consider the extent to which high heels are essential or appropriate to do a professional job, it will be no bad thing.

All the signs seem to point to the fact that harnessing and managing individual freedom is increasingly going to be an essential component of business success in these times of rapid change.

So here's a pithy quote from British historian Christopher Hill (Century of Revolution).

"Only very slowly and of late have men come to realize that unless freedom is universal it is only extended privilege."