I had the privilege of an exclusive interview with Paul Moore after the Jersey International Business School’s Compliance and Economic Crime Symposium in November 2011.
Mr Moore was Head of Global Risk at HBOS but was dismissed in 2004 for warning the board of the dangers of its excessive risk taking and its aggressive sales culture. Much has been written on the case, so I thought it useful to hear his view on how to improve culture and ethics to prevent similar issues arising.
Naomi Cohen: Corruption, anti-money laundering, corporate governance and risk all boil down to ethics. There has been a lot of convergence over recent years and whilst it is relatively fashionable it seems to be the way things are going. You say you feel it needs to be regulated, but how would you envisage auditing whether firms are actually doing what they say rather than waiting for something to go wrong? How do we make sure firms are on the right track and going in the right direction?
Paul Moore: The starting point is to do qualitative analysis within the organisation – I’m not talking about small or tiny little companies, but where they are societally important. Obviously they might be a small company in Jersey which could have a big impact on the island’s reputation, but that is about getting under the skin and assessing the culture as to whether or not people in the organisation itself think that the organisation is ethical. Which is partly about just open questions, but it’s also about whether the systems and controls that are already put in place, in the name of ethics, are in fact real or whether they’re just a front or just words on paper. So you start with that.
Naomi Cohen: With the move towards principles-based regulation and the risk based approach, the underlying idea is that regulators could ease back on having so many rules and that the overall concept is that we conduct ourselves in an ethical manner…
Paul Moore: Yes, this goes back to the point I was making just a moment ago, which is, you’ve got to then check the culture. The second thing to do is check the quality, the technical quality of those working in the control functions and whether they know what ethical really means. With those two things you’re well on the way (if you don’t have those things you know it doesn’t matter what’s on the governance system, it won’t work.)
Naomi Cohen: Some say that ethics is ‘fashionable’ and politically expedient, but can you truly embed ethics across an organisation or is it fundamentally a problem of society that has lost its ethics?
Paul Moore: That’s a very good point. Let’s be clear about this, human nature does have an inclination when money is involved to love the money over other things. That’s why, I’m afraid, you can’t just leave it to the conscience of the individuals. That’s why you have to………. continues
If you would like to read the rest of this interview with Paul Moore, you can subscribe here for a free online copy of Strategic Intelligence. Issue 2 will be released in October 2012.
Paul Moore is in Jersey on Wednesday 4 July 2012 to discuss some of the reasons behind the financial meltdown of 2008. An Evening of Film & Discussion will take place at the Jersey Arts Centre, involving a screening of the award-winning documentary Inside Job. Tickets can be booked directly on 700444.