Wells Fargo and Code of Conduct

Your Organizational Code of Conduct – Do Words and Actions Align?

 Yes…your organisation’s Code of Conduct applies to EVERYONE!
Every one of us has worked for an organisation at one point or another (and hopefully you do right now) which proudly proclaims that they are an ‘Employer of Choice.’

Employers of Choice

For me, the moniker of ‘Employer of Choice” can be achieved when the following five characteristics have not only been met but are continually experienced within the workplace:

  1. Inspired Leadership
  2. Unique Company Culture
  3. Focus on Growing Talent
  4. Strong Sense of Accountability
  5. Aligned Human Resources Practices along with Excellent Execution


Does it need to be in writing?

The journey towards this goal often begins with a strong verbal and written statement delivered from the highest point in the organisation. This is often accompanied by the purchase and display of colourful posters about teamwork touting the benefits of working together and singing from the same song sheet.
The official version of that commentary will exist in your organisation’s Code of Conduct Policy. However, the existence of a Code of Conduct is not enough to stop bad behaviour.  The Code must be rigorously and continuously enforced and supported by the organisation’s culture as well.
If a company’s upper management isn’t either following or enforcing the Code, then the business has a big problem and is another step closer to headlines.

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Passenger plane above the clouds.


Code of Conduct Enforced – Wells Fargo?

You may have heard that Wells Fargo has recently agreed to pay $190 million in settlements after complaints that thousands of its employees created unauthorized accounts using existing customers’ credentials.
It appears that with Wells Fargo at least a culture of compliance and ethics did not trump an environment of hitting sales goals at any cost.
There are those organizations where the practice of flouting such Code of Conduct rules may be deeply ingrained, rendering the document less than useless.

The Emperor’s New Clothes and Wells Fargo

Often, Human Resource Officers and compliance professionals have a very hard job because they have to tell upper management what it does not want to hear. The famous Hans Christian Anderson story, The Emperor’s New Clothes springs to mind…
In recent years, thousands of Wells Fargo employees allegedly set up 2 million deposits, credit cards, and debit accounts without consumers’ knowledge—in violation of the Dodd-Frank Wall Street Reform and Consumer Protection Act—to earn more pay and meet sales goals. The Dodd-Frank Act prohibits unfair, deceptive, and abusive acts and practices by financial institutions.
The bank agreed to pay:

  • $100 million fine to the Consumer Financial Protection Bureau’s Civil Penalty Fund
  • $35 million to the Office of the Comptroller of the Currency
  • $50 million to the City Los Angeles
  • $5 million to customers who were wrongfully charged annual or overdraft fees

In the period from January 2011 to March 2016, Wells Fargo fired 5,300 employees – which represents 1% percent of its workforce – for “inappropriate sales conduct,” according to Aimee Worsley, a spokeswoman for the bank.
“We regret every interaction that was not handled properly,” she said, adding, “The number of instances and team members involved represent a very small portion of our business.”
It is still 5,300.
Wells Fargo has now created and delivered an updated, company-wide Code of Ethics and Business Conduct from its Office of Global Ethics and Integrity:
They have had a code of ethics previously, and they have conducted annual training and teach its

Underwater view of iceberg with beautiful polar sea on background – illustration.

employees methods for reporting their concerns, such as by using the company’s anonymous ethics line.
However, despite these things being in place, one cannot help but look at the bank’s widespread violations of consumer-protection laws. It’s gross abuse of trust shows that this system was not working at all.
So, what is the message for all of us?
Well, the focus of this article has been the Code of Conduct issue at Wells Fargo, but think about other
aspects of your workplace…..particularly around the issue of treating people respectfully and the matter of bullying and harassment. I know you have a policy but is it reflected in how people treat each other?
Let’s go back to my list from the beginning of the article:

  1. Inspired Leadership
  2. Unique Company Culture
  3. Focus on Growing Talent
  4. Strong Sense of Accountability
  5. Aligned Human Resources Practices along with Excellent Execution

How does your organization score?
If you scored 5 out of 5……..give yourself a huge pat on the back…but whatever you do, do not take your foot off the gas pedal.

“He who was honoured yesterday, and stops practicing today, will lose tomorrow.”
Author Unknown

 Align your actions with your statements and you’ll be just fine……


About the Author:

Phil Eastwood is a former London Bobby who brings a thirty-five year career in policing to his role as Senior Partner of Fiore Group Training, a recognized leader in training top North American organizations. Phil is lead author of workplace training courses in respectful workplace training, workplace violence employee training, and leadership training seminars.

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