Page 11 - The Banks Summary (H)

“Ethical programs “must be linked to material
incentives in order to be effective,” he wrote.

Any deviation from the ethics program, “even if
financially lucrative, must be punishable by

nonpayment or clawback of bonuses,” he said,

adding, “Sharp practice that complies with the

law but causes reputational damage should be

penalized.” (1)

The cycle of corruption is based on three elements

money, power and policy. The banks were not

immune from this cycle particularly if there were few

effective checks in place to limit the cycle’s impact.