I am joined in this five-part series by Caterina Bulgarella. We are discussing the recently released white paper by SAI Global, entitled “Predicting Risk: A Strategic Culture Framework for the C-Suite” (the “White Paper”). Bulgarella is a cultural architect and ethics collaborator with SAI Global and the author of the white paper. In this white paper, she introduces a strategic cultural framework which compliance professionals and companies can use to not only help them assess their ethical culture but, equally important, a framework to map ethics to their business process in a manner which improves ethics and compliance and improves overall business processes leading to more robust efficiencies and greater profitability. In Part IV, we consider the Wells Fargo fraudulent accounts scandal within the structure of the framework.

Bulgarella began by noting that the culture determinants that created systemic risk were largely in the red zone, presaging Wells Fargo’s cultural and ethical failures. However, while the culture determinants that shape ‘Delegation of Ethical Dilemmas’ were solidly red, Wells Fargo did possess some degree of ethical capacity, as demonstrated by the fact that several employees tried to blow the whistle. In terms of culture maturity, Wells Fargo oscillated between the conditions of immature and ambivalent; the two culture types that expose an organization to high levels of risk.

When there is a discussion around tone at the top and middle, we are referring to the extent to which leaders and managers acknowledge ethical principles and behave in a way that is consistent with those principles. This leads to the manner in which leadership and power are exercised in an organization, which is a huge component of the culture of an organization and these two huge components of a determination of whether the organization is delegating ethical dilemmas or not as well as the nature of those dilemmas. The type of pressure that may arise from senior and middle are all very relevant.

The next step is to see how senior leaders and middle managers shape any ethical dilemmas. Bulgarella related that if a leader holds an ethical belief but provides a different set of signals in their leadership style, it may well create a set of competing priorities. This can lead to the types of pressure we discussed in prior posts that may lead to ethical lapses.

Saying something like “just get it done” may well blind a leader or manager to tradeoffs. Bulgarella characterized this as a “form of motivated blindness” which has an interesting way of manifesting and resolving itself. Finally, any form of abusive conduct when it comes to leaders and managers is likely to weaken ethical principles.

So how did a company whose corporate values included integrity, respect and principled performance fall into such disrepute? According to the white paper, it actually began in the 1990s when the then Chief Executive Officer (CEO), Dick Kovacevich, “told Fortune magazine that banks had to figure out how to sell money. He believed that financial instruments were consumer products, the same way “… Wal-Mart sells socks or Home Depot sells screwdrivers. Much like those businesses, financial services is huge ($1.9 trillion in assets) and fragmented.”” Unfortunately this innovation for the bank was not matched with its ethical capacity as regional and business unit autonomy led to not only increased sales pressure but almost slavish devotion to the internal sales theme “8 is great” which required salespersons to sell eight Wells Fargo financial products to every Wells Fargo customer; whether they needed or even wanted them. Finally, stakeholders began to engage in retaliatory behavior to those employees who raised ethical concerns that fraudulent accounts were being created.

Utilizing the framework, the culture coordinate of delegation of ethical dilemmas has the following observations.  The determinant of Principals of Conduct noted, “Wells Fargo’s internal and external values were strongly at odds. On the one hand, the company proclaimed its commitment to the customer and fostering trust. On the other, it pushed employees to sell ‘customers as many products as possible.’” Under the determinant Leadership & Power, regional, local and business unit leaders used their influence to force overly ambitious sales goals on employees. Finally, under the determinant of Reward & Sanctions, “Incentives were tied to cross-selling: Salespeople received between 15% to 20% of bonus compensation if they met their sales goals. Though roughly 5,000 salespeople were let go between 2011 and 2016, these layoffs touched only 1% of the workforce.”

In the culture coordinate of Ethical Capacity the white paper noted the following observations. Under the determinant of Ethical Ownership, it stated, “The company’s official position was that the businesses owned ethics, yet senior leadership framed the scandal as a ‘compliance and operations’ problem.” Under the determinant of Ethical Reasoning, it stated, “The ethics program trained employees to spot conflicts of interest and provided them with a Code of Conduct—valuable but inadequate resources to help employees cope with the sales pressure they experienced daily.” Finally, under the determinant of Ethical Voice was the following, “Wells Fargo fostered a culture of threat, intimidation, and retaliation to discourage employees from speaking up. Five percent of the workforce eventually joined forces to file a petition that asked the company to discontinue its cutthroat culture.” Bulgarella concluded by relating, “What’s interesting, however, is that the Wells Fargo story is a cautionary tale for leaders in general because it demonstrates how they can be in a way victimized by their own ambitions, innovation and vision. This is something worth keeping in mind. The science tells us that it’s not always the case that unethical outcomes derive from malicious intent. You may give into an excessively ambitious yet very enticing vision.”

Tomorrow we conclude with a look at the ins and outs of ethical reasoning and then take a veiled look into the future.

For a full copy of “Predicting Risk: A Strategic Culture Framework for the C-Suite” click here. For more information on SAI Global, click here.

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