Salz Review - Wall Street Journal

95
Salz Review
An Independent Review of Barclays’ Business Practices
― Measuring progress with tools which include regular audits of customer,
leadership, employee and stakeholder opinions.
Recommendation 5: Monitoring progress
Barclays should set clear targets against which to assess progress on embedding
the values necessary to build a strong ethical culture. Progress against these
targets should be measured through employee, customer and other stakeholder
surveys and should be reported regularly to the Group ExCo and Board for
discussion. Barclays should also communicate its progress more broadly as part
of its commitment to greater openness and to support its efforts to rebuild
public trust.
8.65 We want to draw particular attention to the importance of monitoring. The Board
should consider establishing a programme of assurance to enable it to assess the
extent to which the organisation is living up to its values. The Board and senior
management should receive regular reports on progress, breaches of values and the
code of conduct, and the use employees make of the escalation and
whistleblowing procedures. Indeed, throughout this report we have emphasised the
usefulness of seeking internal or external assurance or validation of important
people, pay and governance processes. Combining this assurance with appropriate
public communications of the results will contribute to Barclays’ ability to restore
trust.
8.66 Success will require the values to be supported by a revised code of conduct and
reinforced by a common approach to professional standards. The values must be
evident in internal and external communications – and customers, too, should be
clear what behaviours they can expect from Barclays.
8.67 It is common for companies to set out their own standards of conduct in codes
which govern their business practices. In banks, these can get overwhelmed by the
detailed rules which necessarily apply to the conduct of the myriad of specific
transactions which banks undertake. We believe that Barclays would find it helpful to
prepare a code which collects in one place the standards to which it wishes to hold
itself accountable in the conduct of its business and by which it wishes to be judged
by customers, regulators and the public more broadly.
8.68 For such a code to be effective, it must be a living document, owned and developed
by those to whom it will then apply. We would expect a code of conduct to:
― Be owned by the Board and the bank’s leadership;
― Describe in simple language the high standards of behaviour expected of all
those who work for Barclays and how such standards can contribute to
Barclays’ success;
― Clearly reflect the bank’s purpose, vision and values;
― Reinforce the obligation of staff to speak out; not just when things go wrong,
but also to promote things which go well;