Internal Controls and Accountability – Corporate Culture Necessities

September 18 2011


 This week another “what is going on” happened in the financial industry.  This time it is UBS and 31-year-old UBS trader Kweku Adoboli who is accused of rogue trading with estimated losses now closer to $2.3B.  The activity had been occurring for the last three years but according to UBS it just recently uncovered the activity.  Sadly, this comes just a few years after the financial crisis of 2008 and UBS’ commitment to improve risk-controls and management system after it had a $50B write-down.

Accountability and risk managementwere areas of opportunity for UBS back in 2008 and part of the commitmentOswald Grübel, CEO made when he joined in 2009 to improve the risk management.  Fast-forward to September 2011, and apparently the culture is deeply rooted with folks who are working against the mantra of improved operations and risk management or so it seems.

UBS’ story is too familiar to those following the market, corporate culture and the financial industry.  In fact UBS’s story is eerily similar to Société Générale SA andJérôme Kerviel, who racked up a $7.2B loss doing the EXACT same thing.  Kerviel was accused of making fake trades to hide his losses and repeatedly deleted those trades just before inspections, re-entering them afterward.

If you read Kerviel’s and the Soc Gen story, Kerviel will tell you that his leadership knew what was going on and he alleges even helped circumvent the system controls to allow him to make incredibly large trades given his previous successes.  Others were also involved, knew what was going on and in fact left the business shortly after the discovery.  Regulators on the Soc Gen case, The Bank of France, made 17 routine on-site investigations of Soc Gen in the two years prior to Kerviel’s capture and did not detect the matter.

So what is the answer to protect business owners, investors, customers and employees?  First off businesses today are operating in a much more complex environment and with a weaker economy.  When knowledge and money are scarce, we see the true ethical fabric of people and corporate cultures.

Knowing that we have complex and fast-paced environments, and financially weaker economics, we have to acknowledge that financial controls, IT security, risk management and a “do the right thing” culture are critical to ensuring protection of economic value.

As leaders, I would recommend the following to help create a culture of accountability and oversight:

1)  Automation of controls is good but it alone will not do it.  Human observation is critical to catch activity when systems do not.  In the cases I have been involved in; it was the person who has a funny feeling that triggered the review.

2)  Instill in all levels of management the understanding and expectation of risk management as part of their core responsibilities.

3)  View new processes, systems, people selection all with the eye of risk avoidance.  How can we ensure our data is protected, our systems are secure, our people support a culture of taking care of each other, the investors, the customers and the broader economic community?

4)  If you find a flaw, promote it, tell others so they know how it happened, how it was fixed, and that leadership is always on the lookout for other errors.

  1. If it is a system error, do a full sweep of the systems to inventory and determine if others are out there.
  2. If personnel related, investigate how rooted the infraction is on the culture.  Usually people cannot commit a crime alone…typically there are others who at least know about it if not participated in the act.  Determine the depth and breadth of the web of knowledge.

UBS, the world’s largest private wealth manager said no client’s positions were compromised.  However its reputation has been seriously harmed and with their letter to clients this weekend they attempt to provide some assurances “We fully understand this incident has caused you concern.  We too are very disappointed, and we assure you that UBS is taking the matter extremely seriously.”

Well, what about the letter to its shareholders that lost $2B in operating income, or the 3,500 employee force reduction announced in August with a value of $2B which will appear to cover the loss or the broader market that is teetering in its confidence of the financial industry and market in general?

This was not a single person acting alone in a cone.  Several people either activity or passively through lack of controls and accountability played a role in the situation.

We as leaders of companies must understand we are all connected…when we create an environment of strength, values, sustainability and corporate citizenry then we create our own destiny of greatness.  Looking away is not an option for us.  If internal controls and accountability are not on your short list as a leader….this is your wake up call to make some changes.  Too many people are counting on us.

 

 
 
This article has been viewed 309 times.