The IBCB entered our second full year of existence in April 2020, just as the reality and the enormity of the Covid-19 pandemic globally, and nationally, was becoming apparent.
Given our purpose of working with our member banks to build trustworthiness in order to assist the industry in regaining public trust, it was clear that the manner in which our member banks supported their customers, particularly the vulnerable, through the Covid-19 crisis would be a critical determinant of how they, and indeed the IBCB, would be perceived into the future. As a result, we refined our strategic priorities for the year to ensure that these reflected the impact of the pandemic on bank customers and staff from a behaviour and culture perspective. Our Board also decided to increase its frequency of meeting over the year, to review and challenge the manner in which our member banks were responding to the emerging issues for bank customers and staff with a view to assessing whether these responses were reflective of the behaviour and culture expected of IBCB member banks.
We were pleased to see the proactive response of our member banks to supporting their customers at the outset of the pandemic through the prompt introduction of payment breaks. In total over 150,000 repayment breaks were granted, which was the result of a huge effort by bank staff – both at the front line in branches and in other functions – and an achievement for which all involved can be justifiably proud.
A key role of the IBCB is to measure progress on behaviour and cultural change in our member banks. We conducted our first such research in 2018 with bank customers and wider stakeholders as well as with bank staff. In order to assess how issues identified in 2018 had evolved in the intervening period, we developed our revised approach to assessment over the course of 2020. We partnered with Edelman Intelligence and Karian and Box in the development of these surveys which were run in February and March 2021 under the banner of ‘éist’. We selected the Irish word éist, which means listen, because in our discussions with bank customers and staff we frequently hear that people want banks to listen to their views more and then act on that feedback. Further details on the results of our 2021 surveys are set out later in this report and full details can be found on our website.
We are very pleased that our survey of Bank Staff shows strong progress has been made internally across all IBCB member banks since our last assessment in 2018. It is clear, however, from the results of our customer focussed survey, that internal changes in culture have yet to resonate externally with a significant majority of bank customers and the public in general. Achieving this is crucial for the future of the industry and for overall pride levels of staff. Trust is the key currency of change in the banking sector, and it must be earned by the banks to be recognised by the public.
The IBCB knows that public perception will take time to change, but the results of our staff survey show that change is possible. Given recent announcements regarding the composition and structure of the banking industry, significant regulatory sanctions, and the prevailing social and economic issues that society has faced, it would be surprising if perceptions of banks had improved materially. The truth is trust levels amongst the public are not where they need to be. The IBCB is determined to continue to facilitate cultural change in the banking sector in Ireland, that sees these trust levels improve.
The results of our surveys and the ensuing actions to address them will shape the focus of our work programme for the coming year and beyond.
A further key highlight of the past year was the development and launch of our DECiDE decision-making framework in September 2020.
The business of banking is founded on trust and ethical behaviour is a cornerstone of trust. The manner in which decisions are made is a key barometer of an institution’s ethical conduct. To gain trust, an institution’s internal and external stakeholders must have confidence that decisions, at all levels, are made in a fair and transparent manner. DECiDE (described in more detail later in this document) is designed to be a practical decision-making framework aimed at staff at all levels in banks, from the top down. The framework prompts staff to consider a range of issues when making decisions such as the impact of group dynamics, personal bias, the importance of diversity and inclusion, the need to consider the potential risks associated with short-termism versus more long-term and sustainability considerations etc.
The IBCB is now entering our third year of existence and it will be a year marked by continued change for the wider industry and the IBCB itself. Two of our member banks have announced their intention to withdraw from the market in the coming period, Covid-19 has accelerated the transition to digital banking by ever growing numbers of customers with an associated impact on branch networks, the economy is gradually reopening but many business and personal customers will need continued support from their banks. In addition, the Government has published the heads of the Senior Executive Accountability Regime (SEAR) legislation and we have seen a number of material acquisitions by member banks.
The IBCB recognises that from time to time there will be commercial decisions taken by our member banks which may result in both negative (and positive) impacts on specific customer and/or staff cohorts. While it is not the role of the IBCB to focus on the commercial aspects of these decisions, we are of course concerned with whether the decisions are fair and how they will be implemented in the context of the behaviours the IBCB promotes. In response to these ongoing changes, the IBCB has developed a series of Guiding Principles (‘the Principles’) for our member banks to adhere to, as relevant, where there are significant changes in operating models and/or activities resulting in material impacts on bank customers, and/or staff, and/or the wider market. The Principles are composed of five broad categories;‑ 1. Behaviour & Culture; 2. Corporate Citizenship; 3. Communications; 4. Structured Listening and Consultation and 5. Supports. These principles will form a core part of our activity throughout the remainder of 2021 and 2022 and will enable the IBCB to play a strong role in ensuring that positive behaviour and culture lies at the heart of strategic decision-making in our member banks resulting in fair customer and staff outcomes.
The IBCB was established in response to the material behavioural and cultural failings that contributed to the Tracker Mortgage issue in Ireland. Over the past two years the Central Bank (CBI) has completed its investigation of Tracker Mortgages in three IBCB member banks and imposed significant fines. It is anticipated that the remaining two investigations will be completed in the coming year. It is critical that there are real and lasting lessons learned from these investigations. Our activities focussed on building trustworthiness are founded on this and post the completion of the CBI’s investigations, we intend to publish our views on how IBCB member banks have learned from the issues identified by the CBI.
Finally, I’d like to acknowledge the work of our small core IBCB team over the past year. Despite the pressures caused by the pandemic including remote working, distance from overseas family, Zoom meetings and home-schooling, they have each helped to deliver on all of our objectives for the year and I thank them for that.