The Man from FCPA has seen a lot of strong statements from top management, but when a chief executive likens non-compliance to cancer, you know it is serious. But last week, Bill Winters, the chief executive of the UK bank Standard Chartered, did just that when he announced that he had taken steps, and would continue to do so, to stamp out the "cancer of complacency and lax controls" at the financial institution. As reported by the Financial Times, “Winters delivered an ‘angry’ address to its 1,500 top managers and sent several staff memos condemning transgressions that include inappropriate financial dealings with colleagues and excessive expenses.”
Most interestingly, Winters also noted there were internal control failures in both risk management and culture. Winters sent out what the FT termed “conduct memos” which were entitled “#knowtherules” and the FT reported that in one such conduct memo Winters stated “some senior managers willfully disregarded our policies for personal gain…I am deeply disappointed and angry.” Yet even more than simply saying and writing words, the FT noted “the bank is considering clawing back bonuses from 150 current and former senior staff for compliance and risk-management breaches.”
This really is about as dramatic as it can get in the staid world of banking. However imagine the power it would have and the message it would communicate within the organization if the bank does claw back such bonuses. This is more than setting the ubiquitous ‘tone at the top’. This is actually putting your money where you mouth is for the institution.
This type of message by a CEO could have a very powerful impart for non-financial institutions as well. When was the last time you heard of a CEO complaining publicly that senior management was not following policies, procedures and internal controls? In the view of the Man From FCPA, this is certainly a welcome change; even if I find the comparison to cancer strong.