The questions Ian Narev has to be asked
This article first appeared in the opinion section of the Australian Financial Review on the 7th August 2017. Click here to view that version.
The word “litany” is almost an understatement when describing the ethical failures that have besieged the banking and finance industry. Financial planning, life insurance, rate fixing and now abetting money laundering (granted the latter two are still the subject of legal proceedings). By now those of us questioning the efficacy a royal commission would be finding it extremely difficult to defend our positions.
At tomorrow’s results announcement, Mr Narev will face questioning about this latest incident. Analysts and journalists alike will want to get a view on the veracity of the allegations, the potential size of the liability, and how CBA’s systems, processes and procedures failed to pick up the range of failures detailed in AUSTRAC’s statement of claim.
More important will be trying to get to the heart of the cultural issues that incubate and sustain these types of incidents. I would like to propose a series of questions that try and unpack three of these issues.
Firstly, the role of targets. In all these scandals, a focus on hitting targets and making money seemingly takes precedence. An obsessive focus on targets doesn’t just result in people cutting corners to achieve goals, but can literally blind people to other more important concerns, like legal and ethical obligations.
Mr Narev, were the targets associated with the roll out of Intelligent Deposit Machines (IDMs) aggressive? Were they strictly enforced? What happened to people who hit their targets? Missed their targets? Did local leaders make hitting targets a priority, creating an “at any cost” approach? And which people were promoted and held out to be champions of the business? Were they those who consistently hit targets but compromised their ethical and legal responsibilities?
Secondly, the role of the executive and other senior leaders. It is rarely the case in these incidents that executives are duplicitous and knowingly engage in, condone or turn a blind eye to unethical conduct. Rather, it is their failure to act when there is even the slightest suggestion of wrongdoing that sends a powerful message. In the words of Professor Max Bazerman from the Harvard Business School, executives need to be “first class noticers”. And unfortunately for executives, hindsight is a savage judge.
Mr. Narev, were you or your team aware that CBA were receiving and were slow to respond to requests for information from law enforcement agencies about suspected money laundering activities? If so, how did you respond? Also, was your executive team tracking the bank’s adherence to its AML program? Were they aware of the significant growth in deposit volumes through IDMs? Was this questioned? Were there any concerns raised?
Finally, the failure to listen to those who speak up. An unfortunate repercussion associated with systemic ethical failures is that people who have raised concerns are not listened to. Worse still, they are shunned, and made to feel that their opinions are not valued. Alternatively some who harbour concerns remain silent, feeling that speaking up is a futile exercise.
Mr Narev, were there any concerns raised about the way the CBA was dealing with suspicious or threshold transactions through the internal whistleblower program? Or through local leaders in the retail business? How were these concerns addressed? If you or your team were not aware of the issues that AUSTRAC have documented, doesn’t this say something about the willingness of CBA employees to speak up?
It is these types of questions that are rarely posed in the post-mortem of an ethical failure. Addressing the shortcomings in processes and procedures is unquestionably important, but it is the response to these questions that provide a far richer picture of the environment that encouraged and supported the conduct.
Indeed, these are questions that bank executives should be asking on an ongoing basis. By doing so and addressing the issues that invariably surface, they will go a long way towards creating environments that are more resilient to ethical failure.