The Efficacy of HR Role as Ethics Guardian: The Commonwealth Bank of Australia

Subject: Business Ethics
Pages: 20
Words: 5593
Reading time:
22 min
Study level: PhD


Creating a set of ethical standards and maintaining them during communication with other stakeholders is a crucial step in the development of a business organization. Although often overlooked, ethical principles designed by a company hold it together and serve as the foundation for the decision-making processes occurring in its context. Therefore, focusing on the tools that will allow an organization retains its values and ethical standards in the context of the global economy is an essential task that a company leader must carry out in order to advance the firm in the target market. As the case of the Commonwealth Bank of Australia (CBA) shows, the role of an HR manager as the ethics guardian of an organization is essential since it helps the members of a company retain their corporate values and prevent them from choosing the options that will ultimately compel them to commit corporate fraud.

Exploring the role of the company’s HR manager as the ethics guardian, one must keep in mind that the specified task implies the necessity to defend the values mentioned above in front of not only resistant staff members but also business leaders who may refrain from making the correct decisions and, instead, succumb to choosing the easiest option as opposed to the right one. In other words, the role of HR as the guardian of corporate ethics may demand that the HR manager should have the courage to assume the role of an ambassador of good and ethical practices in the workplace environment.

Seeing that the refusal from making ethical decisions damages not only a company’s profits but also its reputation, which is detrimental to its functioning in the long term, HR managers must assume the role of advisors and decision-makers when addressing ethical dilemmas in the context of an organization. The case of CBA shows quite graphically that there is an urgency to reconsider the role of HR managers in the corporate environment. Particularly, their function as guardians of the corporate values and ethical standards must be maintained so that employees could receive a powerful impetus to follow the established ethical principles and moral norms.

The Case of CBA

The case of CBA’s money laundering has recently become one of the most infamous reveals in the history of business along with Enron’s scandal (Tai & Chuang 2015). According to the details of the case, the members of CBA engaged in money laundering by carrying out the transactions that were linked directly to the offshore businesses owned by the specified company members and located in Europe, Asia, and the United States (‘CBA accused of 50,000 breaches of money laundering laws’ 2017). Apart from undermining the position of CBA in the realm of the global market, the specified situation has also affected the organizations extensively:

The civil proceedings follow an investigation by Australia’s financial intelligence and regulatory agency, AUSTRAC, into the use of intelligent deposit machines which, it is claimed, became the outlet of choice for criminal syndicates to shift offshore cash from drug deals. (Pash 2017, par. 4)

A closer look at the situation in which the members of CBA have found themselves will show that the problem concerns primarily the failure of promoting the appropriate ethical standards as well as the mismanagement of the key transactions carried out in the CBA’s environment. Although seemingly concerning a technology-related issue, the instance of fraud at CBA is a glaring example of why the HR management should be positioned as the ethics guardian of the organization. By failing to recruit the people that would have accepted and respected the company’s ethical standards, as well as fostering the specified ethical principles among new staff members, the HR manager of CBA made the fraud possible.

The technique that was used by the members of the organization who were involved in the fraud was, later on, labeled as the “cuckoo smurfing syndicate” (Eyres 2017, par. 3). The specified phenomenon implied that a large number of people should be involved in a network of deposit-making schemes; thus, the instances of fraud could not be detected with the help of traditional control tools (McKenzie, Baker & Mitchell 2017). Furthermore, the approach known as piggybacking was deployed to carry out transactions with international funds without the approval of the owners (Wadlow 2017). The term can be defined as the act of following customers in their choices of transactions by using the client’s information to file a specific order (Wright 2017). Particularly, piggybacking allows one to “control information in the acknowledgment messages of individual operations to inform the coordinator and, subsequently, the other participants about any potential execution infections” (Al-Houmaily 95). As a result, one gets a chance to use the available information to benefit at the expense of unsuspecting customers.

In-Search of Moral Disengagement Roots

Looking back at the situation in an attempt to understand at which point a crucial mistake was made, one must admit that the company’s policy regarding the role that HR played in it was flawed from its foundation. The lack of emphasis on the needs and motivations of employees has affected the way in which the latter perceived organizational behavior standards and corporate ethics (Rodgers, Söderbom & Guiral 2015). Put differently, it was the absence of the strategy for coordinating the personal and professional growth of the employees that facilitated the further development of negative attitudes that prompted the idea of corporate fraud, as Young, Dworkis and Olsen (2016) point out.


The lack of focus on self-achievement combined with the failure to enhance the significance of meeting corporate needs can also be viewed as one of the factors that have contributed to the downfall of the organization and the creation of the environment in which further progress became impossible without the instance of corporate fraud. Indeed, a closer look at the corporate standards that were established at CBA to the time will reveal that the firm has been failing to provide its staff members with an opportunity to express themselves appropriately and, therefore, recognize their further progress as the members of a global company. The introduction of self-achievement principles is bound to create an environment in which further progress becomes a possibility, and where the employees are likely to develop the skills for self-directed learning, As a result, a team of competent experts that acquire new skills and knowledge on a regular basis can be built. However, unless controlled by the company, the concept of self-achievement may turn against the organization, as in the case of CBA. Without a proper emphasis on the importance of teamwork and striving toward a common goal, the idea of self-achievement was turned into a concept of using all available tools to advance oneself in the corporate environment.

In the specified scenario, it was the task of the HR manager to create an environment in which the needs for self-actualization and self-achievement could be balanced with the recognition of the corporate needs. Particularly, the HR manager should have built the corporate culture and corporate ethics standards where the goals of the staff members would have been aligned with the needs of the company and was committing fraud would have implied going against not only the corporate needs but also one’s own interests. Like the example provided by Karatas-Ozkan, Nicolopoulou, and Ozbilgin (2014) shows, there is a strong need for an organization to understand the significance of a directed promotion of self-achievement among the staff members. In fact, the authors argue that the lack of emphasis on the financial gains for the staff members allows organizations to create an environment in which disadvantaged groups of employees can explore their opportunities: “It has been argued that the lack of formal equal opportunity policies in SMEs should not hastily be interpreted as a sign that SMEs are totally unaware of equality issues or that they do not manage diversity” (Karatas-Ozkan et al. 2014, p. 170). On the opposite, “as their limited financial needs make them more sensitive to the cost-benefits of employing disadvantaged groups” (Karatas-Ozkan et al. 2014, p. 170). Teaching the staff to explore and fulfill their potential in the context of an organization is a crucial step toward enhancing the quality of the delivered services and providing the company’s members with an additional motivating factor and, therefore, the means of keeping their engagement levels high. Similarly, the identified framework allows maintaining the employees’ corporate loyalty levels high and, therefore, fosters the concept of the corporate values and ethics as the foundational principles according to which decision-making processes should occur (Boddy, Miles, Sanyal & Hartog 2014). In other words, the idea of a company’s profit would have become inseparable from one of the employees, which would have prevented the instance of fraud. Therefore, the role of an HR manager would have been pivotal in preventing the specified corporate crime from occurring (Oyewunmi, Osibanjo, Falola & Olujobi 2017).

At this point, one must address the issue known as the conflict of self-interest and business interest. Declaring the uselessness of self-interest in the context of the global economy realm would be wrong since the subject matter serves as a powerful impetus for not only entrepreneurial endeavors but also the tendency to improve one’s skills and acquire new knowledge and abilities to stand out among competitors in the global market. The gravity of failing to pursue self-interest-related ideas becomes especially evident when considered through the lens of self-employment: “The incentive to free-ride would be powerful among entrepreneurs because they are subject to competition and thus forced to pursue self-interest in order to survive” (Jensen 2017, pp. 6-7). However, in the context of an organization where the interests of the staff members are guarded and protected, the unceasing focus on self-interest, as opposed to business interest is likely to lead to detrimental effects. Disregarding the significance of personal interest completely, however, would also be a mistake that CBA cannot afford to make at the moment. Indeed, by dismissing the needs of its employees as irrelevant, the company is likely to expect the same results, i.e., the development of the propensity among the staff members to plot corporate fraud as the means of profiting of the company (Cumming, Johan & Schweize 2017). Therefore, a careful balance between recognizing the importance of the employees’ financial needs and the goals of the organization should have been established. Herein lied the role of the HR manager, who should have assured the employees that they will be provided with an opportunity to not only earn increasingly large amounts of money based on the pace of their professional growth but also have a chance to experience a career development (Alfes et al. 2013). If the members of the company had realized that the organization was ready to offer them extensive options for personal and professional development, they would not have experienced the need to use financial schemes for quick money.

Financial Gains

On the one hand, defining financial goals that set the bar for the performance levels within an organization high is a crucial step toward maintaining the quality of performance high and keeping customer satisfaction levels consistent. On the other hand, without a moral compass, a company may succumb to deploying the tools that can be regarded as deeply unethical to attain the set goals. The fact that CBA justifies its course of action by pointing to the rise in its profit margins and performance levels indicates that the current approach to ethical decision-making may be inherently wrong in the CBA environment. Particularly, the official statement of the company is as follows: “The Board notes that it has no reason to believe that the allegations arose from deliberate or unethical behavior, or any commercial motive” (Condie 2017, par. 1). The fact that the organization has its financial priorities straightened out should be deemed as a positive one, yet the consistent focus on financial gains without the adoption of any ethical ideas that could have supported the specified vision and directed it toward a more reasonable course of actions. Indeed, a closer look at the implications of the organizational policy will reveal that the managers could not recognize the fault in their choice of actions; particularly, the members of Enron did not see the corporate fraud as something to be concerned about (Melé, Rosanas & Fontrodona 2017).

Indeed, a closer look at the way in which self-interest and business interest could be aligned will show that there is a chance to promote active investment of the staff members in the company’s progress and at the same time address the employees’ financial concerns accordingly. Carson (2003) uses the stakeholder theory as the foundation for analyzing the effects that the incorporation of personal and corporate interests into the HR strategy for managing the staff members, therefore emphasizing the importance of recognizing the employees’ aspirations and concerns:

Both the shareholder theory and the stakeholder theory need to add a constraint that prohibits executives from pressuring, enticing, or permitting professionals who work for corporations to act contrary to the moral codes of their professions or engage in fraud or deception. (Carson 2003, p. 390)

In other words, the author states clearly that, unless a firm recognizes the financial needs of its staff, employees will start seeking their own ways of fulfilling their financial needs, yet the choices that the staff members will make in the latter scenario is unlikely to align with the goals of a company (Farndale, Pai, Sparrow, & Scullion 2014). The incorporation of the stakeholder theory perspective, indeed, allows developing a better understanding of why CBA has faced a complex ethical problem. The theory points to the necessity to take the personal needs of all participants involved in a specific business into account. Otherwise, the untimely demise of an organization becomes very likely. In the scenario that can be observed at CBA, a glaring disregard of the needs of the staff members could be observed.

Milking the Business

One must bear in mind that it was the lack of initiative that made CBA so helpless in the face of corporate fraud. The absence of any HR-related control over the threats that the inefficient corporate values triggered in the organization was truly glaring. A closer look at the scenario that developed in the CBA environment will reveal that the company did not take any initiative to reduce the possibility of fraud: “AUSTRAC is alleging that the Commonwealth Bank did not take any steps to assess the risk of money laundering or terrorism financing via IDMs for three years after they were rolled out” (Ryan, 2017, p. 8). Therefore, the company has evidently been deploying the strategy known as milking the business, i.e., focusing on retrieving a series of short-term revenues as opposed to building a framework that would gradually propel it to better performance and, therefore, a consistent increase in its profit margins (Lin, McDonough, Loin & Lin 2013). According to the explanation provided by Dasilva and Trkman (2013), the specified process implies that increasingly high investments are made into the processes that are bound to bring the company an immediate profit (Dasilva & Trkman 2013). However, the authors also stress that, while allowing to exploit the company’s opportunities successfully, the identified approach is likely to lead to a failure to minimize the firm’s exposure to both external and especially internal risks (Shim 2013). With all assets of the organization being utilized to enhance the financial profits, there are very few opportunities to invest in other essential aspects of the firm’s operations that will allow promoting the necessary values among the staff members.

By minimizing the investments made in the development of the necessary ethical standards, CBA failed to promote responsibility and moral integrity among its staff members. A recent study points to the necessity to invest extensively in the process of designing an ethical culture within an organization (Palomino & Martinez-Canas 2014). Therefore, it is imperative that a certain part of the corporate assets should be used to develop a comprehensive HR strategy that could serve the purpose of guiding the staff members to make ethical decisions in the context of the corporate environment. Herein the role of the HR manager would have lied in the CBA case; particularly, the HR manager should have used the available financial resources to build an environment in which the employees would have accepted the essential principles of ethical decision-making (Shapiro &.Stefkovich 2016). As a result, the foundation for preventing the instances of corporate fraud would have been designed. At this point, one must admit that suppressing the staff’s ability to even think of corporate fraud as a possible solution is barely possible. However, the role of the HR manager would not have concerned eradicating the very concept of fraud from the employees’ minds. Instead, the culture in which the CBA employees would have dismissed the idea from the very start and would be fully aware of why the concept of corporate fraud is unacceptable should have been created (Soltani 2013). It is imperative that staff members of any organization should make a conscious decision to abstain from unethical and fraudulent actions; otherwise, they will be tempted to try abusing their power in the organization once they are exposed to the environment where the control over their actions is not very tight (Lefkowitz 2017).

Therefore, in hindsight, the fact that the staff members were allowed to exploit the organization’s assets and view CBA as a cash cow as opposed to an organization with a rigid set of ethical standards, its own goals and vision, and a mission aimed at attaining a certain degree of success can be deemed as the primary problem that must have led to the development of the environment in which fraud was an option.

The Politics of Control and the HR Role

It is crucial to maintain the right balance between executing control over a company and its key processes and providing the members of the firm with enough flexibility to improve their performance and help them retain their motivation. Therefore, building a policy of control adopted in a business organization is a rather challenging task for HR managers (Voegtlin & Greenwood 2016).

The opportunities for both giving employees enough room for decision-making and controlling the essential processes within a firm can be opened once value-based HR practices (VBP) are introduced into the corporate environment. By definition, VBP can be deemed as the tool for enhancing the communication process between an employee and a manager by removing the factors that may inhibit successful negotiation, e.g., administrative norms and the associated constraints (Tuan 2016).

The use of value-based HR practices, therefore, should be deemed as the primary tool for exerting the policy of control in an organizational environment. When considering the role that CBA’s HR team should have played in the identified scenario, one must admit that introducing a rigid set of control tools is a crucial step toward facilitating security in the workplace and reducing the possibility of fraud occurring in the context of an organization.

In retrospect, the HR manager of CBA could have considered building the model for an ethical business culture that would have served as the basis for the decision-making based on the results of a survey conducted among the staff members. Indeed, adopting the ethics promotion model that would have been alien to the corporate environment of CBA could have been another mistake that could have led to even more drastic outcomes. Moreover, by using a survey as a means of collecting feedback from the staff members, an HR manager would have been able to invite the employees to participate in shaping the cultural values and ethical norms of the organization. With the increase in involvement rates among the employees, it could have been expected that they would view the ethical standards as the ideas that they would actually use when making important company-related decisions in the workplace environment. Indeed, the feeling of involvement, unity, and significance of their contribution to shaping the company’s ethics and vision would have prevented the employees from deviating from the required mode of behavior and considering the possibility of corporate fraud.

HR Role – Adding Value through Guarding Values

As stressed above, in the identified situation, it was crucial that the key values and ethical standards of the organization should have been held as the top priority of the company and the foundation for the decision-making process. The role of an HR manager would have been crucial in the case under analysis. Particularly, an HRM would have had to add value by safeguarding it and helping the organization retain its philosophy and ethics used for decision-making. Thus, the staff members would not have succumbed immediately to the idea of committing fraud in the context of the organization.

One must admit that the process of adding value is typically linked to the idea of designing an appropriate marketing strategy and, thus, building the basis for the increase in the customer retention rates, as well as the further promotion of the company’s products and corporate brands (McMurrian & Matulich 2016). However, after detailed scrutiny of the subject matter, one will realize that there is a tangible connection between the identified phenomena. Particularly, the opportunities for creating brand equity that the process of adding value creates contributes to leads to the creation of long-term value in the organization (Malik 2014). As a result, a company is capable of reinforcing the significance of its corporate philosophy, including the set of ethical standards used for decision-making, and a deep understanding of the company’s needs, such as the necessity to maintain its integrity in the face of a crisis and make sure that the staff members should follow the existing ethical standards fully.

It was, therefore, the task of the HR manager to add organizational value by guarding it efficiently. As soon as corporate values lose their weight in the eyes of employees that are supposed to follow the specified ethical and behavioral standards, the efficacy of the standards in question will drop exponentially. Therefore, it is paramount that the HR manager of the organization where corporate values start losing their credibility should reinforce the importance of the identified values and standards accordingly. For this purpose, an HR manager must define the value chain in the organization. In other words, the connections between the existing values, the corporate ethics, its culture, vision, mission, etc., must be established properly. Furthermore, it is the responsibility of an HR manager to introduce the principle of value appropriation into the context of the organization. By definition, the subject matter implies that the corporate value is not only captured but also kept safe from the competition. In the case under analysis, the trust-based relationships between the staff members and managers should be viewed as the value in question, and it should have been the task of the HR manager to build it successfully. Apart from keeping the company together and preventing the instance of corporate fraud, the identified approach would have helped CBA increase its competitiveness rates in the realm of the global market (Hörisch, Freeman, & Schaltegger 2014). Particularly, the authors of a recent study on the subject matter see value appropriation in the following way:

As the ability to capture but then also protect the returns to value creation from the forces of competition. It considers processes that guard against the threats of “value leakage” caused by the spread of competitive intelligence incursions – more knowledge, in more heads, under less control – and the passing of information through a supply chain of knowledge sharing networks.” (Sparrow & Makram 2015, p. 10)

Thus, the HR manager at CBA should have explored the potential of value retention as the means of building it. With the employees being involved in the process of value building, the feeling of personal involvement would have compelled them to follow willingly the standards set by the organization. Furthermore, they would have realized that the specified step is the right one to take in their situation.

Corporate Ethics Program

In hindsight, the HR manager should have built a framework that would have allowed keeping the values of the organization intact. The specified change would have prevented the development of the attitudes that led to the idea of corporate fraud. Raising ethical awareness among the staff members should have been the focus of the corporate ethics program; particularly, the active promotion of ethical principles based on transparency, compliance with the law, and consistent communication between the employees and the managers should have been emphasized extensively. As a result, the instance of corporate fraud would have been avoided successfully. However, introducing a corporate ethics program now would not be a moot point since it will help keep the company afloat even after the incident.

The design of the corporate ethics program should start with the revisiting of the current code of ethics. Particularly, the principal corporate values should be included in it so that the staff members could use them in the future as the foundation for decision-making in the context of the organization. The change in the code of ethics should be followed by the ethics training for employees. Thus, they will be able to develop flexibility and a deep understanding of the corporate ethical standards, both of which will be necessary to make important decisions at CBA. The introduction of a reporting mechanism will help keep the track of the problems that the staff members will face, whereas the use of audits will serve as the means of checking whether the new ethical principles are followed closely. Finally, a well-developed investigation system should be designed so that possible instances of fraud should be identified early and investigated successfully.

The Specter of Indoctrination

In retrospect, some of the policies of the organization, as well as its focus on the necessity to cut the financial expenses taken in the process of meeting customers’ needs, should be blamed for a shift in employees’ values and the further realignment of their priorities so that fraud was viewed as a possible line of actions. Indeed, a closer look at the environment in which the staff members were forced to operate will show that the participants were indoctrinated to focus on the costs that the organization had been suffering, as well as on the profit margins of the firm (Ferguson 2014). The exponentially high concern for sales and fees, which could be observed in the environment of the organization, was flawed from its very foundation since it made the staff members not only realize that there were significant loopholes in the firm’s financial security system but also dismiss the corporate integrity, the organization’s values, and the foundational ethical principles for the sake of a personal gain.

It could also be assumed that the active promotion of corporate governance as the basis for managing large companies should be blamed for the lack of control over the ethical choices made by the company’s members. Indeed, as the study by Cohan (2002), where he examines the problems faced at Enron and the factors that led to its infamous and untimely demise, the author concludes that the propensity toward executing the principles of corporate governance without exerting tight control over the decision-making processes at the execution level was the problem that became the foundation for Enron’s failure and is bound to doom other organizations that follow its tracks. For instance, when Enron’s case was analyzed, one of its members mentioned the corporate governance system as the factor that restricted their opportunities for supervising the essential processes carried out in the context of the organization:

Enron’s former chief executive, Jeffrey K. Skilling portrayed himself as ignorant of the company’s questionable practices in testimony before the same House committee. He said, “This was a very large corporation. It would be impossible to know everything going on.” (Cohan 2002)

The inability to execute corporate governance fully without missing some of the essential operations and relationships in it points to the fact that the management of human resources at CBA left much to be desired at the specified point in time. Thus, it can be assumed that the specter of indoctrination that could be observed at CBA did not allow fostering the necessary qualities among the staff members and promoting the required ethical values on a corporate level. In hindsight, CBA should have addressed its indoctrination issues by focusing on the active promotion of corporate values such as responsibility and ethical behavior.

Indeed, the fact that the staff members were forced to focus on sales at any cost without paying attention to any other issues associated with the firm’s operations pointed to the fact that the company’s planners did not have an opportunity to rethink the choices that they were making, The indoctrination strategy used in the company, therefore, could use a significant improvement. Instead of viewing the sales and the further increase in the firm’s profit margins as the ultimate goal, it could have introduced the ideas that would have served to meet the needs of all stakeholders involved as the guiding principles that defined the corporate decision-making process.

Separation of Thinking from Execution

The problems associated with corporate governance and the lack of control over the decision-making processes occurring at the execution level have triggered a discord between the latter and the processes associated with thinking and analyzing. The resulting unwillingness to correlate the available choices with the company’s ethical standards has caused the downfall of CBA. For instance, the propensity toward considering self-interest-based goals as the priority that should define the managers’ choices as opposed to business interests needs to be listed among the key problems that CBA has developed over the past few years. Indeed, a closer look at some of the most recent business scandals will show that an organization faces the threat of deviating from its ethical standards and having its members considering the possibility of fraud at the point where the processes of thinking are separated from the execution of particular steps.

There is no need to stress the fact that the strategic thinking model chosen by an organization should align with its execution model (Dragoni et al. 2014). As far as the strategic thinking framework is concerned, it should be based on the organization’s ethics, philosophy, vision, and standards so that it could define the choice made by the staff member. The mode of execution, in turn, must be shaped by the strategic thinking approach so that the long-term consequences of the managers’ actions should be fully understood and used as the foundation for defining the further course of actions to be taken by the organization (Muralidharan 2015). Therefore, the framework of strategic thinking should be inseparable from the mode of execution and, which is even more important, both should be rooted deeply in corporate ethics and values. Thus, the basis for the successful functioning of a firm can be created (Hahn 2013).

CBA, however, misaligned its strategic thinking with the choices of execution approaches. Particularly, the strategic thinking framework seems to have become far too detached from the way in which the key processes are implemented in the context of the organization. As a result, the company manager failed to correlate the goals of the organization and the options that they had when carrying out the decision-making process. Instead, the managers focused on the opportunity of personal gain, thus, violating the very foundation of CBA’s ethics.


Since the propensity to steer away from making ethical choices is likely to occur in a global company in an environment where the significance of the corporate ethics becomes smaller compared to the need for personal gain experienced by the staff due to a drop in the workplace control intensity, it is essential that the HR manager should remain consistent in executing the principle of workplace ethics and promoting it to the employees, as well as the company’s leaders. Thus, the premises for the company’s staff to succumb to making unethical choices will be removed from the context of the company’s environment completely. Consequently, the threat of failing to meet the set ethical standards will be addressed successfully.

Despite the fact that the role of HR managers as the guardians of ethics in the realm of business companies is often underrated, they have the potential to help a company retain its ethical values and remain morally unambiguous even at the time of a crisis. For this purpose, though, an HR manager must confront not only the staff members but also possibly its leaders in an attempt to focus on ethical decision-making. By reminding the members of a firm about the significance of the corporate values, an HR manager will build the basis for further compliance with the key organizational ethical standards and, therefore, prevent instances of corporate fraud.

Creating an environment in which fraud cannot possibly be committed is rather unlikely since accidents tend to happen even in the safest setting. However, it is crucial to make sure that no instances of glaring negligence toward the promotion of corporate values with the help of the HR team should take place. The role of an HR manager must not be underrated; otherwise, an organization is unlikely to survive a crisis without some of its members considered the possibility of using their position in the firm to their advantage. Once the importance of the HR manager as the keeper of the company’s traditions and the ethics guardian of the company is recognized, the premises for managing a crisis successfully and preventing the incidents of fraud can be built successfully.

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