Process without the right culture will fail
Headlining at Trustee Exchange, Peter Moore the only UK banking employee to speak out publicly about irregularities he witnessed from inside of a bank, stressed that the crisis at HBOS was caused because there was a completely inadequate separation of powers and balance of powers between the executive and all those accountable for overseeing their actions. He warned that an organisation can have the best processes in the world, but if there is unethical behaviour and an indisposition to challenge, they will fail.
Key governance lessons learned are the need for:
- A sound culture,
- The capability of control functions (audit, compliance, internal audit)
- Corroboration in oversight work
- Up to date company laws
Good governance is about sound compliance and structures, clear and consistent policies, processes and procedures and a healthy culture supported by appropriate behaviours. Often governance reviews look at fiduciary matters, at systems and do not seem to acknowledge that culture, values and behaviours underpin strong governance.
Without appropriate behaviour or conduct, governance will fail irrespective of structures that are fit for purpose or clear processes.