Culture Eats Controls for Breakfast – Why True Resilience Depends on Behavior as Much as Technology – Assurance Mandate Series – Part 4
David Nichols – Co-Founder and Executive Director of the DVMS Institute
The Real Blind Spot
Peter Drucker famously said, “Culture eats strategy for breakfast.” In today’s digital era, it’s just as true that “Culture eats controls for breakfast.”
No matter how many frameworks you adopt or certifications you earn, if your organizational culture undermines accountability, transparency, or adaptability, resilience will break down when you need it most.
In Part 3 of this series, we discussed how silos weaken resilience, using Equifax and Colonial Pipeline as examples of organizations that had controls and compliance artifacts but still failed. In this article, we revisit those examples — and include Boeing — to make a more precise point: it wasn’t the lack of controls that caused their failures. It was the culture that made those controls ineffective.
Why Culture Gets Ignored
Boards and executives tend to trust what can be easily measured. Audit scores, certification badges, patch rates, and compliance dashboards all share a common trait: they simplify complexity into numbers that can be neatly included in a board packet. These numbers provide reassurance. They appear as progress. They indicate control.
Culture, however, resists easy classification. It cannot be summarized by a single number or reduced to a neat dashboard. You can’t simply list “transparency,” “accountability,” or “adaptability” on a spreadsheet and expect the absolute truth to show through. Culture is about how people actually act when no one is watching, whether they speak up when they see a vulnerability, whether they speak up about uncomfortable truths, and whether they prioritize organizational resilience over their own comfort or career risks.
How many messengers have you shot?
This is precisely why culture often gets overlooked: it’s more challenging to measure, harder to evaluate, and tougher to justify to regulators. However, ignoring it can be dangerous because culture is what determines the effectiveness of the controls leaders depend on.
The paradox is unavoidable. Culture often influences the success of controls more than the controls themselves. A perfectly crafted patch management policy fails if the culture accepts delays. A crisis playbook is ineffective if the culture discourages escalation. An audit framework is meaningless if the culture rewards “passing the test” rather than building resilience.
When leaders restrict governance to what fits on a dashboard, they confuse activity with assurance. In doing so, they close their eyes to the crucial factor that determines whether their organization can withstand disruption.
Case 1: Boeing — Compliance Without Candor
Boeing’s 737 MAX program underwent rigorous regulatory oversight, received certifications, and had documented processes in place. On paper, the company appeared to be compliant. However, the culture, one that valued delivery schedules and cost targets more than transparency and engineering concerns, weakened those controls. Engineers who raised alarms were pushed aside. Safety became just a checkbox to meet, not a core value to uphold. The outcome was two devastating accidents that no checklist could have prevented.
The lesson is clear: even the strictest controls are pointless if culture silences the feedback that makes them work.
Case 2: Equifax — The Patch That Culture Ignored
As noted in Part 3, Equifax’s 2017 breach wasn’t caused by a lack of frameworks. The company had established compliance programs and conducted regular audits to ensure adherence to these standards. The failure occurred when a known vulnerability remained unpatched for months. Controls were in place, but the culture did not ensure accountability or follow-through. Risk management was viewed as an administrative task rather than a core enterprise priority. When the breach happened, it resulted in billions of dollars in costs and irreparable reputational damage.
Equifax teaches us that culture determines whether controls are acted upon or left to gather dust.
Case 3: Colonial Pipeline — When Culture Sees Cyber as “IT’s Problem”
The 2021 Colonial Pipeline ransomware attack, also discussed in Part 3, was not caused by a lack of technical safeguards. Instead, it reflected a broader culture that viewed cybersecurity as solely an IT issue, rather than a matter of organizational resilience and risk management. Leadership didn’t fully incorporate cyber considerations into governance or business continuity plans. When the attack occurred, it wasn’t just the systems that failed; it was the organizational mindset that failed as well.
The lesson: a culture that isolates cyber from the business causes resilience to fail at the moment of truth.
DVMS: Making Culture Visible
What links Boeing, Equifax, and Colonial is straightforward: controls were in place, but culture dictated performance. Each organization had certifications, frameworks, and compliance systems in place. However, without a culture rooted in accountability, transparency, and adaptability, those controls offered false assurance rather than true capability and resilience.
Here’s why the Digital Value Management System® (DVMS) is essential. DVMS does not see culture as something intangible. Instead, it makes culture visible by integrating behavior into governance. In DVMS, a policy is not just written down; it is reinforced through workflows and verified with assurance evidence. A control failure in IT isn’t merely documented; it is escalated as evidence of governance, revealing whether the culture exacerbates or neglects issues.
By creating continuous feedback between governance, performance, and assurance, DVMS ensures that culture isn’t just declared — it’s demonstrated.
Culture as a Systemic Variable
Culture is not “soft.” It is a systemic variable that determines whether frameworks gather dust or become lived practices. It decides whether controls exist on paper or actually work under stress. It is the invisible architecture of resilience.
With DVMS, culture becomes an integrated part of the system — monitored, reinforced, and assured like any other capability. Leaders no longer need to assume culture is resilient; they can now demand evidence that it is.
The Executive Question
Executives and boards must ask themselves difficult but essential questions:
- Do our audits tell us whether employees escalate risks — or whether they bury them?
- Can we prove that our culture reinforces resilience — or are we assuming it does?
- When disruption strikes, do our people adapt responsibly — or do they scramble to avoid blame?
Without clear answers, you are not governing by assurance. You are governing by appearances.
Closing the Gap
Controls can be copied. Frameworks can be bought. Technology can be outsourced. But culture must be governed — and too often, it isn’t.
This is the gap that boards and executives must address. Most leaders are happy to comfort themselves with certifications and dashboards, confusing activity with assurance. However, true confidence doesn’t come from artifacts; it comes from proof that your people, processes, and systems will withstand disruption when it occurs.
Culture distinguishes teams that hide mistakes from those that escalate them. It separates employees who wait for permission from those who act with accountability. It differentiates organizations that collapse when the playbook fails from those that adapt in real time. In every case study we’ve seen, including Boeing, Equifax, and Colonial Pipeline, the issue wasn’t just a technical failure. It was a cultural failure. The organizations were compliant on paper but fragile in practice.
This is why DVMS is so crucial. It does not treat culture as an afterthought or simply a slogan on a wall. Instead, it integrates culture into the governance process, making behavior visible, measurable, and actionable. It compels organizations to view culture as a systemic variable, one that can either reinforce resilience or weaken it.
For boards and executives, the message is clear: you can’t govern with artifacts alone. You must lead the culture that determines whether those artifacts are effective when they are most needed. And you must ask for evidence, not just of controls, but of the culture that supports them.
Resilience is not something you create with binders, frameworks, or compliance audits. Instead, it is experienced, strengthened, and managed on a daily basis. That is the gap DVMS addresses, transforming culture from a hidden risk into a visible source of strength.
👉 Next in the Assurance Mandate Series: DVMS as a Journey, Not a Big Bang — how organizations evolve from compliance artifacts to assured resilience.
About the Author
Dave is the Executive Director of the DVMS Institute.
Dave spent his “formative years” on US Navy submarines. There, he learned complex systems, functioning in high-performance teams, and what it takes to be an exceptional leader. He took those skills into civilian life and built a successful career leading high-performance teams in software development and information service delivery.
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