ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Compliance and Risk

Culture Equals Capital

December 7, 2018
Reading Time: 4 mins read

By Monica C. Meinert

In 2015, news came out that that German auto manufacturing giant Volkswagen had engineered its so-called “clean diesel” vehicles to pass an emissions test in an indoor lab setting, while knowingly concealing the fact that once on the road, the cars would emit nitrogen oxides up to 40 times over the permissible limit.

The scandal reached the highest levels of the organization—Volkswagen’s CEO resigned shortly after the news broke, and the company ultimately paid $25 billion in fines to the U.S. government in one of the most egregious cases of corporate misconduct in recent history.

These kinds of scandals are, of course, not limited to the automobile industry. Since 2008, for instance, large financial institutions around the globe have paid more than $320 billion in fines connected to misconduct. But beyond the financial penalties, employee misconduct can have serious repercussions for an organization’s reputation and can damage the confidence of customers and shareholders.

Conduct risk and culture

Conduct risk is not a new concept by any means, but banks have only recently begun to look at it as a discrete risk category. The Federal Reserve Bank of New York defines conduct risk as “the potential for behaviors or business practices that are illegal, unethical, or contrary to a firm’s stated values, policies, and procedures.”

There’s an inextricable link that exists between ethical conduct (or lack thereof) and the culture of an organization. “Culture is a form of capital—it’s an intangible asset that you need,” explains Kara Tucker, enterprise ethics strategic manager at SunTrust and a panelist at ABA’s Regulatory Compliance Conference earlier this year. She uses an example of rocks in a glass jar. “The rules, laws and regulations are rocks in a glass jar. Culture is water. It fills the cracks, it tells us how we need to act.”

When culture is weak, inconsistent or toxic, it increases the chances of misconduct occurring within the organization. So how do banks build strong internal cultures and stay on the right side of conduct risk?

1. Create an environment where problems can be escalated

A key indicator of a strong internal culture is whether employees believe that they can speak up if there’s a problem. Regardless of the bank’s size, Tucker emphasizes that employees “need places to report inconsistencies in culture.”

While SunTrust uses a third-party provider to manage its anonymous hotline, she says that smaller institutions can be successful running a program internally to handle whistleblower complaints. Of critical importance is ensuring that employees are educated on how to report—and understanding what will happen when they do.

“We have a whole campaign around speaking up,” adds Aprille Savarese, SVP for conduct, security and financial crimes risk management at Zions Bank. Part of that process involves meeting with leadership teams around the bank so that they understand that allegations don’t disappear into a “black box.”

It also involves making sure employees who do report feel like they’re being heard and that investigations take place in a timely manner. Savarese—who monitors Zions’ third-party whistleblower hotline—says she’ll occasionally “mystery shop” the bank’s hotline, calling in a fake complaint to ensure that information is being collected responsibly and escalated in a timely fashion and through the correct channels.

2. Have strong communication practices

Building a strong organizational culture starts with strong communication, Savarese says. “Having a clear communication path is critical, and it needs to be multiple layers.” That means that everyone—from the bank’s senior management team down to branch management needs to be able to clearly and consistently communicate the organization’s expectations to their staff.

At SunTrust, Tucker also tries to embed messaging about ethics into employees’ everyday tasks. These can be things as simple as running ethics messages on desktop screen savers or popping up a compliance reminder when employees fill out expense reports.

3. Pay attention to subcultures

Regardless of the bank’s size, bank leaders should also pay close attention to subcultures that form within the organization. Whether it’s a single department within a local community bank or at a branch miles away from a regional bank’s headquarters, subcultures can have a significant effect on employee attitudes and behaviors—both positive and negative. “People imitate what they see others doing,” Tucker says. “The goal is to figure out where the subcultures are.”

Zions Bank, for example, has more than 400 branches in seven different states, and Savarese says one of the key challenges is making sure that there is a consistent understanding and application of the bank’s values. Ultimately, the goal is to “make sure you have a sound culture, and not a lot of subcultures.”

4. Use reporting and metrics

To gain a holistic understanding of an organization’s culture and potential conduct risk exposure, bank management and compliance teams can work to pull together data points from across the enterprise. By monitoring things like compensation data, performance reviews, employee surveys, corrective actions and consumer complaints, it’s possible to start identifying trends and potential weaknesses. “Any time we can look at behavior, we have an opportunity to put metrics round it,” Tucker says.

Another key source of data? Employees on their way out the door. “Exit interviews are goldmines,” she adds.

5. Get buy-in from employees

At the end of the day, the success or failure of a bank to build a strong internal culture depends on whether its employees truly believe in the organization’s mission and values. As she recently worked to update SunTrust’s code of conduct, Tucker says it was important to make sure that it would be something employees could easily understand and relate to.

“I used ‘we’ language to get the buy-in, and I gave behavioral examples so that it’s tied to what people are doing.” She also added a formal non-retaliation policy to the beginning of the code of conduct—a signal to employees that they should feel safe to report any misconduct they observe.

Ultimately, Tucker says: “if you have strong morale around complying and doing the right thing rather than finding the line and skirting it, you have a form of capital.”

Tags: EthicsRisk management
ShareTweetPin

Author

Monica C. Meinert

Monica C. Meinert

Monica C. Meinert is a senior editor at the ABA Banking Journal and VP for executive communications at the American Bankers Association.

Related Posts

Banking agencies pledge more scrutiny of core provider business practices

Banking agencies pledge more scrutiny of core provider business practices

Compliance and Risk
September 11, 2026

The federal banking agencies pledged to step up oversight of third-party core providers whose business practices “unreasonably limit” community banks from conducting due diligence or from negotiating contract terms that address the banks’ business needs.

CISA releases updated guide on insider threats

CISA releases updated guide on insider threats

Compliance and Risk
September 11, 2026

The guide gives organizations a current look at insider threats and practical steps to develop or enhance an insider threat program, according to CISA.

Podcast: Remembering 9/11, a quarter century later

Podcast: Remembering 9/11, a quarter century later

ABA Banking Journal Podcast
September 10, 2026

Conversations with two financial industry professionals help illuminate the impact 9/11 had on bankers, the financial system and the whole nation.

FBI publishes first cyber strategy roadmap

FBI publishes first cyber strategy roadmap

Compliance and Risk
September 10, 2026

The FBI released its first “cyber strategy” that outlines the law enforcement agency’s priorities in combating cybercrime and protecting critical infrastructure.

FinCEN releases financial trend analysis on health care fraud

FinCEN releases financial trend analysis on health care fraud

Compliance and Risk
September 10, 2026

Financial institutions flagged approximately $17.5 billion in suspicious activity related to potential health care fraud during a one-year period starting in 2025, according to a financial trend analysis released by FinCEN.

ABA to FCC: Protect critical calls to bank customers

FCC releases draft order to protect fraud alerts

Compliance and Risk
September 9, 2026

The Federal Communications Commission released a draft order that would rewrite the agency’s “revoke all” rule – an action that ABA has long advocated. The FCC will vote on the draft order at its Sept. 30 open meeting.

NEWSBYTES

Banking agencies pledge more scrutiny of core provider business practices

September 11, 2026

Preliminary: Consumer sentiment decreased 3.9 points in September

September 11, 2026

ABA DataBank: The ‘she-conomy’ drives job growth

September 11, 2026

SPONSORED CONTENT

Banking Technology at a Strategic Crossroads

Banking Technology at a Strategic Crossroads

September 8, 2026
Taming AI Agent Sprawl: A Playbook for Consumer Lending

Taming AI Agent Sprawl: A Playbook for Consumer Lending

September 1, 2026
Grow Public Deposits Without the Operational Burden End Fragment

Grow Public Deposits Without the Operational Burden End Fragment

September 1, 2026
Could Your Bank Absorb the Hidden Cost of Running Legacy Systems?

Could Your Bank Absorb the Hidden Cost of Running Legacy Systems?

August 20, 2026

PODCASTS

Podcast: Remembering 9/11, a quarter century later

September 10, 2026

Podcast: Banking the brave new world of college athletics

August 4, 2026

Podcast: Tactics for meaningful strategic planning

July 28, 2026

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.