You cannot poster your way to a new culture, and one of the most senior people leaders in British banking has just said so out loud. Speaking at the CIPD Festival of Work on 11 June 2026, Sharon Doherty, chief people and places officer at Lloyds Banking Group, told delegates something that ought to unsettle every change programme relying on a values campaign. Her words, as reported by People Management on 12 June: “If you are in the middle of a culture change and you’re only focusing on [employee] behaviours, it’s highly likely that your culture change won’t work.”
Doherty is correct, and the correction matters. Culture is not produced by behaviour in isolation. It is produced by the systems people work inside, the symbols leaders make visible, the story told from the top, and the behaviours that result. Lloyds did not run a campaign and hope. It rebuilt the leadership team, rewrote its workforce plans, and over three years trained around 6,000 employees as “catalysts of change”. Within two years, more than half its people, 55%, were new. That is not a poster. That is structural surgery.
The Half That Leaders Quietly Drop
Here is where the lesson usually goes wrong. A leader hears “behaviour alone will not work” and files behaviour under the easy, finished part. Strategy, structure, reporting lines, the org chart, that is the serious work. Behaviour is the assembly that happens once the clever bits are decided. So they pour the budget into the redesign and hand the behaviour to an e-learning module and a town hall.
That is exactly the trap Doherty was warning against, read from the other end. She was not saying behaviour is unimportant. She was saying behaviour-only change fails, and so does structure-only change. You can redraw every reporting line in the bank and your managers will still run the same defensive meeting they ran last year, because nobody ever changed what they do when a colleague raises something awkward. Doherty’s own emphasis points the same way. She told the room to do the hard things early, “because what you can see is the impact it has on engagement”. Engagement is a behaviour signal. It moves when people experience the change in the room, not when they read about it.
Why Telling People The New Behaviour Does Nothing
There is a reason the behaviour half gets skimped, and it is not laziness. It is that most organisations only know one way to address behaviour, and it is the way that does not work. You write the new value, you put it on a slide, you ask people to live it. Roediger and Karpicke showed in Psychological Science in 2006 that being tested on material lifts long-term retention by roughly 50% compared with re-reading it. A keynote about your new culture is the re-reading kind of learning. It feels productive in the room and fades inside a fortnight.
The behaviours a culture change depends on, a manager naming a difficult issue early rather than letting it fester, a leader holding an uncomfortable silence rather than filling it, a junior colleague challenging a senior one in a meeting, are not transmitted by being described. They are acquired the way every hard skill is acquired, by doing the thing, badly at first, with feedback, against a standard. You do not learn to handle a hostile stakeholder by attending a session on handling hostile stakeholders. You learn it by handling one, then handling the next one better. That is the part a values campaign cannot touch, and the part that decides whether the new culture survives contact with a Monday morning.
How We Build The Behaviour Half So It Holds
Because real behaviour change happens through lived experience that makes the memory stick, we build the behaviour half as rehearsal, not broadcast. In a Sidestream programme the central method is not a presentation, it is a scene. A small group, one or two professional actors playing the people the work is genuinely hard with, a defensive direct report, a sceptical executive, a colleague raising a concern that lands badly. The conversation is run, replayed, and run again against named behavioural anchors, until the new behaviour is what comes out under pressure rather than the old one.
That is the difference between our immersive approach and conventional e-learning. A module can confirm someone reached the final screen. It cannot confirm they behave differently when a meeting turns tense. A simulation that puts a manager in the actual conversation, watched and coached, produces the evidence a behaviour-only campaign never can. This sits inside the structural work Doherty describes, it does not replace it. The systems, the symbols and the story set the conditions. The rehearsal is how the behaviour those conditions are meant to produce gets into the people.
The Part That Has To Be Measured
The reason behaviour gets dropped is also the reason it has to be measured, and most programmes measure it at the wrong level. The Kirkpatrick model, the standard framework for evaluating training and reaffirmed by Kirkpatrick and Kirkpatrick in 2016, sets four levels. Level 1 is reaction, did people enjoy it. Level 2 is learning, did they know more leaving the room. Level 3 is behaviour, are they doing the job differently a month later. Level 4 is results, did the business outcome move. A values campaign, at best, reaches Level 1. People liked the off-site. Nobody checked whether a single manager ran a single conversation differently the following Tuesday.
We design for Level 3 from the first conversation, because behaviour is the level Doherty just told a national audience you cannot afford to skip. In Sidestream’s own academic behaviour-change work, building on research from UCL, Cambridge and Bocconi, participants consistently rated their own communication skill well above what trained observers later measured. The confidence was real. The skill was not yet there. A satisfaction score captures the confidence and misses the gap, which is how a culture programme can be loved and change nothing. We replace the happy sheet with a behavioural baseline and a follow-up measure.
Lloyds backed its words with structure most organisations cannot match. Most clients do not have that scale. What every client can do is refuse to treat behaviour as the afterthought. The structure sets the stage. The behaviour is the performance. And a performance is rehearsed, watched and measured, never simply announced.
What We Do About It
Our immersive leadership development and speak-up culture work are built for the behaviour half of culture change, the half that fails when it is handed to a slide deck. If your structural pieces are moving but the behaviour stubbornly is not, that is not a motivation problem. It is a method problem, and it is fixable.
Behaviour alone will not change your culture. Neither will structure alone. The behaviour half has to be rehearsed and measured at Level 3, not announced on a slide and hoped for.
The transformations that hold are the ones where the new behaviour is practised until it is the default, then measured to prove it stuck. Book a call to look at what rehearsing and measuring the behaviour half would mean for the change you are running.
Book a free 30-minute diagnostic call → or read about our research-backed approach.
Source: People Management, “Employee behaviour alone will not transform culture, says Lloyds CPO”, published 12 June 2026, reporting Sharon Doherty’s keynote at the CIPD Festival of Work on 11 June 2026. Get in touch today. We are Sidestream.