By Dean Benard
For many years, investigations in both professional regulatory environments and workplaces focused primarily on individual behaviour. A complaint came forward, an allegation was assessed, and the investigation examined the actions of the person at the centre of the concern. That approach still matters, and people are accountable for their conduct, but increasingly, investigators are being asked to look beyond individual actions to the cultural conditions that allowed those behaviours to emerge, persist, or go unaddressed.
Culture has become a central factor in modern investigations. Not only because culture influences behaviour, but because organizations, regulators, and the public now expect that systemic contributors will be identified and addressed, not ignored. When the focus remains solely on “who did what,” we risk missing the deeper issues that caused the complaint to arise in the first place.
Why Culture Matters in Investigations
Organizational culture sets the context in which conduct occurs. It shapes norms, expectations, communication styles, power dynamics, and the sense of psychological safety that determines whether people speak up or stay silent.
In regulatory investigations, culture can affect whether professionals feel pressure to cut corners, fail to document, or avoid reporting unsafe practices. In workplaces, culture can normalize behaviours that fall short of policy but have become “just the way things are around here.” Investigators increasingly encounter allegations that stem not from a single incident but from a pattern of micro-behaviours, tone, or systemic dysfunction.
When culture becomes unhealthy, it tends to produce “clusters” of issues: high turnover, recurring interpersonal conflicts, repeated complaints about the same unit or leader, or inconsistent application of policies. These are red flags that the problem may be bigger than one individual.
Moving from Incident-Focused to System-Informed Investigations
A culture-informed investigation does not replace traditional fact-finding, it enhances it. Rather than limiting interviews to the immediate witnesses, investigators expand their lens and explore broader context:
- Patterns of behaviour: Are similar issues being raised across the unit or profession?
- Norms and expectations: What behaviours are tolerated, ignored, or subtly rewarded?
- Leadership influence: How do leaders model expectations, respond to concerns, or contribute to the climate?
- Communication practices: Are people afraid to speak up? Do concerns get minimized?
- System integrity: Are policies applied consistently? Are processes trusted?
Investigators must be cautious not to drift into organizational consulting or culture audits, but acknowledging cultural context can be essential to understanding why the alleged behaviour occurred and how the environment shaped it.
Culture-Based Evidence: What It Looks Like
Unlike traditional evidence (emails, documents, timelines), cultural evidence is more nuanced. It may include:
- Recurring themes across interviews, even when not tied to a specific allegation
- Misalignment between stated policies and lived experiences
- Disparities in how different groups are treated or heard
- Fear of retaliation or lack of trust in reporting systems
- Conflicting versions of “how things work around here” depending on hierarchy
The key is to treat culture-related information with the same rigour as any other evidence: categorize it, verify it, corroborate it across sources, and remain cautious about over-generalizing.
The Intersection of Culture and Professional Regulation
Professional regulators face unique challenges when culture becomes a factor. For example:
- A professional may be the subject of a complaint, but the behaviour may reflect broader systemic issues in their workplace.
- Regulatory standards may conflict with workplace norms, placing professionals in untenable positions.
- Regulators increasingly expect organizations to proactively address cultural contributors rather than simply disciplining individuals.
In some cases, a regulator’s investigation may trigger an employer to look at cultural issues internally, or vice versa. The alignment (or misalignment) between these processes can influence outcomes for both the individual and the organization.
When a Culture-Based Approach is Essential
Culture should be considered explicitly when:
- Multiple complaints emerge from the same unit, team, or leader.
- Allegations include micro-aggressions, subtle behavioural patterns, or civility concerns.
- There is evidence of fear, retaliation, or power imbalance.
- Policies exist but are inconsistently applied.
- Witnesses describe conflicting experiences that seem rooted in norms rather than incidents.
In these situations, ignoring culture risks producing an incomplete or misleading investigative outcome.
Balancing Scope: What Investigators Should and Should Not Do
Investigators must balance two responsibilities:
- Stay within the mandate
Investigations are not workplace assessments, audits, or organizational culture reviews. The investigator’s role is still to determine facts related to the allegations.
- Identify systemic contributors when they directly affect the findings
It is appropriate to comment on cultural factors when they:
- Provide necessary context
- Influence credibility assessment
- Help explain inconsistencies in evidence
- Demonstrate recurring patterns relevant to the allegations
The goal is not to redesign culture, but to shine a light on the conditions that shaped the outcome.
Improving Culture to Reduce Investigations
Ultimately, when culture is healthy, fewer issues escalate to formal investigations. Organizations that proactively address:
- Psychological safety
- Leadership capability
- Clear expectations
- Consistent policy enforcement
- Transparent communication
- Anti-retaliation commitments
…tend to experience fewer formal complaints and more effective early-resolution processes.
In the regulatory world, a strong culture within professional settings reduces risk, improves public protection, and creates more stable practice environments. In workplaces, it decreases conflict, enhances engagement, and strengthens trust.
Conclusion
Investigations remain essential tools for addressing misconduct and resolving complex issues. But as workplaces and professions evolve, so too must investigative approaches. By considering the role of culture, without losing sight of individual accountability, investigators can provide more accurate findings, more meaningful insights, and more impactful recommendations.
Culture is not an excuse for behaviour. But it is often part of the explanation. And when we understand that, our investigations become not just exercises in determining what happened, but opportunities to improve the environments in which people work and practice.
