When Culture Kills: Why organisations keep hiring the wrong people (and consultants) to lead culture work — and who pays the price

Dr Anna Kiaos | Discipline of Psychiatry and Mental Health, UNSW Sydney | Founder & Director, Mind Culture Life Australia

In March 2025, a NAB fraud department specialist died by suicide at the bank's Docklands headquarters in Melbourne. Weeks later, a second employee — from a separate team — died by suicide. Both deaths occurred inside an institution that employs approximately 40,000 people and that has, for years, marketed itself as a people-first organisation with strong values and a commitment to employee wellbeing.

These were not isolated incidents. They were the most visible expression of something that had been building for years inside one of Australia's largest financial institutions.

Former NAB employees have described, in documented accounts, a culture that shifted from supportive to punishing: rolling restructures, the attrition of experienced staff, relentlessly rising performance targets, normalised unpaid overtime, heavy monitoring of desk time and leave, and an environment in which raising concerns about workload was not just ineffective — it made you a target.

A Finance Sector Union survey of more than 1,200 NAB employees had previously found that 93 per cent worked more than contracted hours without pay, 87 per cent said this had caused health problems, and some reported hospitalisation from stress. Internal culture surveys, according to former staff, did little to change anything. The bank continued to report strong engagement scores while people were hospitalised, broke down, and in two cases, died. (The relationship between workplace conditions and deaths by suicide is never simple, and no causal determination is made here — these are matters for coroners, regulators and the courts).

NAB is not an outlier. It is a warning. And the warning is not simply about performance pressure or bad managers. It is about a specific and systemic failure in how large organisations approach culture work — and about the catastrophic consequences of getting that wrong.

The Culture Function - More Thought Required

Most large Australian organisations now have a dedicated culture function. They have Chief People Officers, Head of Culture roles, Culture and Capability teams, Employee Experience leads. They run engagement surveys, launch values programs, commission culture assessments and post results to their intranet. They are not, as a rule, short of activity. What they are frequently short of is the conceptual architecture to understand what culture actually does, and what it takes to change it.

The problem is that most culture professionals are trained to understand culture as a branding exercise or a climate intervention. Their expertise runs to engagement strategy, communications, leadership development, and change management. These are not worthless skills. But they are not the skills required to identify the mechanisms by which a culture produces psychological harm, to map the pressure gradients that make certain roles and teams dangerous, or to design controls that actually reduce risk at the structural level.

There is a further dimension to this that is almost entirely absent from how organisations currently frame culture work. Culture is not only a driver of performance. It is also a generator of psychosocial risk. The same cultural conditions that produce high engagement, strong identity and discretionary effort — a competitive performance norm, a sense of collective mission, high social investment in the group — can simultaneously produce overwork, boundary erosion, reluctance to report harm, and the normalisation of conditions that are objectively dangerous. A strong culture, in other words, is not a safe culture by definition. It can be the mechanism through which harm is produced and sustained.

A strong culture is not a safe culture. The same forces that drive performance can, without the right architecture, drive psychosocial harm.

This is the central insight of the Culture Pressure Map™ (CPM) framework, developed by this author from research at UNSW Sydney. The CPM maps organisational culture not as a single climate to be measured and improved, but as a layered pressure system operating simultaneously at three levels: the Shared Ethos of the wider sector or field; the Subcultures of professional groups, divisions and organisational units; and the Microcultures of individual teams and work units. Each level generates its own normative pressures, and those pressures do not always align. The result is a culture that may look coherent from the outside while generating serious psychosocial risk at the points where those pressures collide — in the team, in the role, in the individual.

In an organisation like NAB, the Shared Ethos of the financial services sector — performance, target delivery, cost discipline — plausibly sets the normative field. Subcultures within the bank translate that ethos into local operating norms: the team that works weekends, the manager who monitors desk time, the culture of not complaining. At the Microculture level, individual workers navigate the gap between what the organisation says it values and what it actually rewards. When that gap becomes wide enough, and when the normative pressure to perform overrides the psychological capacity to sustain it, the result is harm. The CPM framework is designed to make those pressure gradients visible before they produce the outcome NAB is now confronting.

When two people die, and the organisation's response is to point to its engagement survey scores and its EAP referral pathways, that is not a failure of bad faith. It is a failure of category. The people leading the culture function do not have the framework to understand what they are looking at.

The Regulatory Shift Has Changed Everything — But Most Culture Leads Don't Know It

Since 2022, Australia has undergone a fundamental regulatory shift in how work health and safety law treats psychosocial hazards. The model WHS Regulations were amended to establish an express obligation on persons conducting a business or undertaking to manage psychosocial risks with the same systematic rigour long required of physical hazards. New South Wales followed with the SafeWork NSW Code of Practice on Managing Psychosocial Hazards at Work. Victoria, a non-harmonised jurisdiction, went further still: the Occupational Health and Safety (Psychological Health) Regulations 2025, which came into effect on 1 December 2025, are described by legal commentators as the most detailed and prescriptive psychosocial regime in Australia to date.

These instruments identify specific hazards — high job demands, low job control, poor support, inadequate reward and recognition, poor organisational change management, workplace bullying and conflict — and require duty holders to eliminate or minimise them through the hierarchy of controls. Critically, they explicitly restrict reliance on information, instruction or training as a primary control. An EAP is not a control. A resilience workshop is not a control. A values refresh is not a control. These are downstream measures that leave the hazard in place and hope workers survive it.

In November 2023, Court Services Victoria was convicted under the OHS Act and fined approximately $380,000 after the Victorian Magistrates' Court found that a toxic workplace culture at the Coroners Court of Victoria had contributed to an employee's suicide and to widespread psychological harm. The employer had EAP services. It had HR policies. It had a culture of some kind. What it lacked was a genuine system for identifying and controlling the psychosocial hazards embedded in how work was designed and managed.

The NAB deaths triggered regulatory investigations. New South Wales legislative amendments that took effect on 5 December 2025 now make a work-related or suspected work-related death by suicide a notifiable incident. Workplace safety regulators in both jurisdictions have signalled that enforcement is intensifying. The cost of inadequate psychosocial controls is no longer hypothetical.

Regulators are not asking: did you offer counselling? They are asking: did you eliminate the hazard?

The culture professionals sitting in organisations like NAB — the people ostensibly responsible for this work — are in many cases not equipped to answer that question, because they have not been trained to ask it. They are measuring performance and engagement, not exposure to risk driven by the culture. They are perhaps running culture performance workshops rather than hazard assessments. They are perhaps building psychological safety programs that address interpersonal dynamics while the structural conditions that produce harm — workload design, performance architecture, role clarity, change management practice — remain untouched.

What This Means for Boards and Officers

The Work Health and Safety Act 2011 places duties not just on organisations as PCBUs but on officers — directors and senior executives who exercise significant influence over the management of the business. Officers have a due diligence obligation that includes taking reasonable steps to understand the nature of WHS operations and to ensure appropriate resources and processes are in place to eliminate or minimise risks.

An officer who delegates psychosocial risk to a culture team that does not understand psychosocial risk has not discharged their due diligence obligation. This is not a technicality. It is the argument that WorkSafe Victoria and SafeWork NSW are now capable of running in court. What this means practically is that the decision to hire a Head of Culture or to structure the people function in a particular way is now a governance decision with WHS implications. A board that receives strong engagement survey results and no psychosocial hazard reports is not receiving assurance. It is receiving the wrong reporting.

NAB's culture function had access to engagement data. At least from the outside, it did not appear to have a functioning psychosocial risk management system. Two people are dead.

The Capability Gap Is Not a Soft Problem

The gap I am describing is not a minor competency shortfall. It is a structural misalignment between what the culture function is designed to do and what psychosocial safety law now requires it to do.

The people doing culture work in large organisations are largely trained in organisational development, change management, positive psychology, and HR strategy. These disciplines are not oriented toward identifying hazards, designing controls, or constructing the kind of evidence-based documentation that satisfies a duty of care under WHS legislation. They are oriented toward building the conditions for engagement, motivation and performance.

Engagement and safety are not the same thing. An engaged workforce can be an exposed workforce. High-performing teams operating under unsustainable conditions routinely show strong engagement scores right up until the point of breakdown — because the culture has normalised the conditions as a mark of commitment, and because the social rewards of belonging to a high-performing team temporarily mask the psychosocial harm being accumulated.

An engaged workforce is not a safe workforce. Engagement measures sentiment. Safety requires you to identify and control the hazard before the harm occurs.

What organisations need, and what most do not have, is culture leadership that understands normative control — the mechanisms by which culture produces compliance, identity, and emotional investment, and the mechanisms by which those same forces generate harm when the system is designed poorly or operates under sustained pressure. They need people who understand psychosocial risk architecture: how work design, management practice, organisational structure and the informal rules of a workplace combine to create or reduce exposure. They need people who can design controls that operate at the systemic level, not just the individual level. This is not a description of most people currently leading culture functions in Australia's large employers.

What Genuine Culture Leadership Requires

The organisations that will avoid the trajectory NAB is now on are not those that add more wellbeing programs to a toxic structural substrate. They are the organisations that understand culture as a psychosocial risk environment and design it accordingly.

This requires, at minimum, four things.

First, a hazard identification process that operates at the level of culture — not just physical environment or discrete incidents. The SafeWork NSW Code and the Victorian Compliance Code both provide taxonomies of psychosocial hazards. The question for culture leaders is: where in our cultural architecture do these hazards live? What are the normative pressures, the informal rules, the performance signals and the management practices that create or amplify exposure?

Second, controls that target the hazard, not the symptom. If the hazard is excessive workload normalised by a high-performance culture, the control is not a resilience workshop. It is a redesign of work and a recalibration of what the culture rewards. If the hazard is low job control embedded in a micromanagement norm, the control is not a mindfulness app. It is a change to how authority is distributed and how management is conducted.

Third, a reporting architecture that gives boards and officers genuine visibility of psychosocial risk — not just engagement scores. This means designing the culture function to produce hazard reports, not just sentiment surveys.

Fourth, culture leadership that has the theoretical and regulatory literacy to do all of the above. This means hiring people — or developing people — who understand culture not only as a performance asset but as a psychosocial risk environment. Who can map the pressure gradients in their organisation at the level of Shared Ethos, Subculture and Microculture — and who understand that a strong culture and a dangerous culture are not mutually exclusive. Who understand the intersection of normative control, psychosocial safety science, and WHS duty of care. This is not a unicorn skill set. It exists. It is simply not what most organisations are hiring for.

The Stakes Could Not Be Higher

NAB's story is still unfolding. Regulatory investigations are underway. Legal commentary suggests the question of whether current WHS frameworks adequately reach workplace deaths by suicide will be tested in the months ahead. The bank has made the standard statements about support and care. It has not, publicly, acknowledged that the cultural structure of its workplace — the relentless performance pressure, the normalised unpaid work, the culture in which raising concerns made you a target — was a designed environment that exposed its people to serious psychological harm.

That acknowledgement would require a kind of culture leadership the function, as currently constituted in most large Australian organisations, is not equipped to offer.

We are at a turning point. The regulatory framework now demands that organisations treat psychosocial risk with the same rigour as physical risk. The enforcement signals confirm that regulators are serious. The human cost confirms that the stakes are real.

The question for every board, every officer, and every organisation that employs people is not whether this could happen to them. The question is whether the people they have put in charge of culture have the framework to prevent it.

Dr Anna Kiaos

Researcher, Discipline of Psychiatry and Mental Health, UNSW Sydney

Founder & Director, Mind Culture Life Australia

Dr Kiaos's research examines organisational culture, normative control, and psychosocial risk. Her Culture Pressure Map™ framework maps cultural dynamics at the levels of Shared Ethos, Subcultures and Microcultures.