.

1. V A R U N | K Y L A | B R I T N E Y | K U S H A L | L I S A
PROBLEMS STATEMENT: Structure and lack of controls of incentive
programs led to corrupt sales practices for
personal gain.
Company
Biggest bank in the USA
What Happened?
Opened 2 Million credit and bank accounts without
customer consent
Critical Issue
Performance Incentives, Goals
How?
Forge Papers, Emails and Signatures

2. STRUCTURE
Organizational Design: Adding an HR team/department that reports to the risk management
committee to reduce pressure from power differentials. Add a whistleblower program allows
anonymity and reports go right to the board.
a. Value: Unbiased third-party intervention available to employees, employees will have a
central place to go to for lodging complaints and make them feel heard without fear of
retaliation.
b. Metric: Overall employee morale and satisfaction benchmark of 80% reached and measured
by employee surveys administered anonymously
Committee Structure: Proper documentation around employees concerns.
a. Values: Transparency in decision making/ consequences of actions
b. Metric:

3. OVERSIGHT
Board: Chair and CEO made into separate roles.
1. Value: independent oversight and ethical behavior.
2. Metric: Audit for authorization, control and review. Audit of
independent relationships.
Committee authority and responsibility: Create independent risk
management committee which maps the balanced scorecard.
1.Value: Ensures fair and ethical compensation incentives.
2.Metric: Incentives tie into values on balanced scorecard. Zero
conflicts of interest in incentive packages.
Managerial/Executive authority: Manager and HR member evaluate
employee with balanced scorecard. Ensure employees are meeting
realistic targets.
1.Values: Reduce conflict of interest and unethical behaviour.
2.Metric: Quarterly reviews for progress towards goals and annual
performance reviews and balanced scorecard for setting bonuses.

4. TECHNOLOGY Technology: Use technology to automate notification controls to
customer for account activities (open, close, transactions, etc.). If
accounts are not active then they are closed.
a. Values: Transparency of account activities and increase of
customer trust
b. Metric: Less than 1.5% of accounts are being reported as open
but not active. Complaints of fraudulent activities based on
receiving text/email notifications decrease by 10% each year.
Infrastructure: IT is separate from the rest of the organizational
design and only department with authorization to update
personal banking information (i.e. phone number, address,
email). Build different levels of security access.
a. Value: Security of information/data is higher
b. Metric: Audit report to ensure all positions have proper
security access as per their job duties.

5. TALENT
Values: Ethical behavior, increased customer satisfaction and
trust, increase employee morale, knowledge and employee
retention and integrity
Incentives: Balance Scorecard Evaluation
Metrics:
•Keeping an client account open and active beyond 1 year
•Customer retention and satisfaction
Principles: Ensuring values are reflected in best practices
and code of conduct.
Metric:
•Employees read and sign off on code of conduct
•Employee and customer retention
Communication and Reporting: Training for employees on
ethical behavior and informing customers on best practices
for their own personal security
Metric:
•How many people are attending training.
•Mandatory quiz at end of training (100% pass rate
requirement)