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Blog series – Andrew Hall

In advance of our event at the Bank of England on 21 March 2017, we asked interested parties to write on the theme: Worthy of trust? Law, ethics and culture in banking…


Note: The views expressed in this blog are the personal views of the author and not necessarily those of the CISI.

Why should we trust our banks? Do we actually trust even our own bank, or banks generally? How deep is that trust; has it been earned or is it rather grudgingly given, accompanied by the feeling that it has not actually been earned?  I rather suspect the latter, which is quite dispiriting. So how serious are our banks in seeking to remedy this and are they likely to be successful anytime soon?

That question of how long it will take to restore trust in banks is one which the CISI has asked audiences at our events regularly since the global financial crisis and the answer has always been ‘at least ten years’. From that, one might deduce that this is a long-term project and it is unrealistic to expect overnight success. But it is now some time since the worst years of the financial crisis. which leads to the question ‘what will success look like?’.

One answer might be when respected surveys of Trust such as the annual Edelman Trust Barometer or ‘Which?’ surveys show a sustained improvement in levels of trust markedly beyond their current level of approximately 50% of respondents trusting banks. Or more prosaically, when we are prepared to recommend our banks to one another as trustworthy or ‘good’ organisations. What, beyond our day to interactions with our own bank,  might influence our response if asked whether we trust banks(ers)?

Since most of us do not have any direct business interaction with actual or apparent interest rate fixers, we are dependent upon being told by the media how wicked they are, or how egregious their offences, without really having any idea or necessarily caring what they have actually done, or what impact it has, if any, on our lives. My point is not to downplay what they have done or its impact, but rather to suggest that our views are possibly being formed by someone else. In most instances, the court cases that are now happening cover events that took place several years ago and banks can argue that they do not represent today’s culture in these organisations. But then how do we know? Why should we take their word for it? Why should we trust them?

And then there is PPI, a subject that must have knocked on every door in the land and where bankers may argue that with the value and number of claims of mis-selling having been paid out, a degree of scepticism on the part of banks over the ongoing level of claims is not surprising. On the other hand claimants and potential claimants have no sympathy for them and such is the absence of trust, consider banks to be ‘fair game’. Billions of pounds of repayments and reparations have not served to restore trust. We use banks because we have to, not necessarily because we want to, or because we trust them again.

As I said earlier, this is a long-term project and banks and the banking industry must accept it, even to the extent that they may feel that ‘ethics fatigue’ has set in. Bob Diamond’s ‘time for remorse and apology is over’ has not yet been accepted by the public.

Andrew Hall, Head of Professional Standards & Integrity, Chartered Institute for Securities & Investment

Senior Managers and Certification Regime

Exploring how the SMCR - and especially Certification - can be implemented in the most effective way across the sector.

The Senior Managers and Certification Regime is a major regulatory change that will affect all banks and building societies. Responding to recommendations by the Parliamentary Commission on Banking Standards, the government and regulators have together developed a comprehensive framework to ensure better accountability and responsibility for behaviour, competence and culture in banks and building societies. The new framework provides an opportunity for the industry to focus on and demonstrate a culture of professionalism. We are working with firms and regulators to facilitate this, including areas where a common approach across firms could support both the objectives of the regime and the skills and development of the people covered by it.


Evaluating whether a more 'professional' approach to banking would improve behaviour and competence across the industry.

The Parliamentary Commission on Banking Standards found that 'banking culture has all too often been characterised by an absence of any sense of collective responsibility to uphold the reputation of the industry', and argued that a greater focus on professionalism could be an answer to this. Working with a leading team at the University of Leeds, we are researching the issues around professionalism in banking. In particular, we are reviewing how professional qualifications are currently used across the sector, and at whether a stronger role for professional bodies, along the lines seen in some other sectors, like medicine or law, would help raise standards. To inform this work and develop a rounded picture of 'professionalism' and what it means in banking, we are surveying banks and building societies, professional bodies and a wide range of other interested groups, including consumer bodies and investors.


Providing an honest and impartial assessment to Boards of progress against objectives on behaviour, competence and culture.

The BSB assessment exercise presents Boards with an objective and impartial view of their firm's culture, identifying where things are working well and recommending areas for improvement. It draws on information not only from Boards and senior teams, but also from employees, investors (or members), trade unions, customer groups and other relevant bodies. In doing so, it will provide constructive challenge to each firm individually, while building a collective understanding of common issues across the industry, or sectors within it. We undertook our first annual assessment exercise in 2015 with ten firms (Barclays, Citi, HSBC Bank, Lloyds Banking Group, Metro Bank, Morgan Stanley International, Nationwide, RBS, Santander UK and Standard Chartered). The BSB itself will not publish individual assessment reports - each firm owns its own report - but key themes and messages will be set out in the BSB's annual report, the first of which will be published in Spring 2016. Given that Board engagement is central to the assessment work, only firms that have their headquarters in the UK are eligible for the full assessment exercise. All firms, including branches of firms headquartered overseas, will however be included in a focused membership-wide survey, which will allow each participating firm to benchmark itself against its peer group.



If your bank/building society has not responded adequately, or in time, to a complaint that you have already made, you can register your complaint with the Financial Ombudsman Service. Which offers a guide on consumer rights when taking a complaint to the Financial Ombudsman Service.


If you have a problem or query relating to your financial affairs, or are seeking personal finance advice or guidance, there is free, impartial information available from the following organisations:


If you work in the financial services industry and are concerned about any activities conducted by your employer or any other firm or individual, you may find the Financial Conduct Authority and the Prudential Regulation Authority's guidelines on whistleblowing helpful. It explains what constitutes whistleblowing, and what procedures are in place to respond to blow the whistle and how your anonymity would be protected. Public Concern at Work, the whistleblowing charity, also offers support and advice to individuals and employers about how to report concerns and how to establish whistleblowing frameworks.


If you are seeking the services of an independent financial adviser, Unbiased may be able to help, or if you are looking for more general financial guidance, the Money Advice Service may be a useful place to start.