When it’s not your hand in the cookie jar

I recently returned from the latest ECI Fellows meeting, which focused on behavioral ethics. This post is part of a series where I share my insights and lessons from the meeting.


Behavioral science has demonstrated that it is easier for people to rationalize unethical behavior when they are not the one doing it.

For example, a child might resist the temptation to steal a dollar at home to buy cookies at school. But if her big sister steals the dollar and offers to split the cookies with her, she is likely to accept them. After all, she didn’t steal the money.

Or take the adults that worked at Wells Fargo. Many of those who supervised the front-line employees opening fraudulent accounts knew what was going on. But they weren’t the ones opening the accounts.

As ethics & compliance professionals, we should be on the lookout for similar dynamics in our organization. It’s often risky to grant approval powers where the pressure and opportunity is greatest (once again, the fraud triangle at play). When we identify a dangerous situation (usually after an investigation), we need to take action either by removing the pressure or elevating the approval/responsibility up the chain of command.

For 5 years, Wells Fargo allowed its supervisors to rationalize the unethical behavior of their direct reports by making sure the supervisors had no part to play in actually opening the fraudulent accounts. Where do you see a similar pattern in your organization today?

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