CBA Case

Commonwealth Bank of
Australia

Figure 1: [Link]

In February 2019 newspapers took aim at the financial services industry in Australia. The
release of report of The Royal Commission into Misconduct in the Banking, Superannuation
and Financial Services Industry, known as the Hayne Royal Commission, on February 4 th sent
shockwaves through a sector. Banks are a crucial part of the Australian economy, their
services make up 2.9 per cent of everything Australia produces, and despite Australia having
a population of only 25 million people, pre-tax banking profit here ranks 6 th in the world.

The 1000-page report produced by the Hayne Royal Commission had brought to light
systemic negative issues in behaviour, culture and practice. The Report made 76
recommendations and 24 referrals for further action, including criminal charges.
Commissioner Hayne was very clear in his opening chapter as to where accountability lay:

There can be no doubt that the primary responsibility for misconduct in

the financial services industry lies with the entities concerned and those
who managed and controlled those entities: their boards and senior
management.

The report argued that effective leadership, good governance and appropriate culture are
fundamentally important for the successful, and ethical, running of financial institutions.
Hayne also noted that culture, governance and remuneration are closely connected. Staff
are not only motivated, but directed, through remuneration policy and practice.

One banking product that came under scrutiny during the Royal Commission was the selling
of consumer credit insurance (CCI). CCI is insurance that covers you if something happens
that affects your capacity to meet the payments on your loans and other credit. CCI usually
covers situations of unemployment, illness, involvement in an accident, and death.

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 CBA Case

Between 2011 and 2018 Australian financial institutions sold almost $5billion worth of CCI,
yet only paid out $1billion in claims. The banks and other institutions signed up
unsuspecting customers who believed the insurance would cover their mortgages, credit
cards and other kinds of loans if they got sick, had an accident, lost their job or died. Little
did they know the hurdles to claims were so high that most would be rejected. It was
“hugely profitable but grossly unethical.” Described as a “profit before people culture”, the
selling of CCI involved aggressive sales tactics and staff who were incentivised to sell as
many products to as many customers as they could.

The shift from banks as being ‘pillars of the community’ to ‘public enemy number one’ did
not happen overnight. Over decades the financial services sector shifted in response to
economic, political and social changes, adapting their strategy, policy and practice to
outperform their competition and deliver returns for their shareholders. As a result,
according to the Royal Commission, they shifted away from the six underlying principles, or
norms of conduct, that the Banking Royal commission identified as essential:
1. obey the law;
2. do not mislead or deceive;
3. act fairly;
4. provide services that are fit for purpose;
5. deliver services with reasonable care and skill; and
6. when acting for another, act in the best interests of that other.

Banks and the financial services industry are crucial elements not just in Australia’s
economy, but in the life of all citizens. Banks carry significant risk for society, they manage
assets in excess of 250% of Australia’s GDP, but are also in a privileged position in our
community. For example, Australian banks were backed by the government during the
global financial crisis. The Australian Parliament notes:

Banks are not just like any other business. They are essential utilities.
People cannot function in modern society without adequate access to the
banking system. They are an integral component of society’s institutional
infrastructure. This has traditionally given banks a certain degree of status
and privilege, and this has survived deregulation to a large extent. This
conveys an obligation to the community.

CBA Board Chairman Catherine Livingstone has said that the financial services industry
carries the most significant risk for society. The degree of regulation, and the fact that
banking centres on the financial wellbeing of individuals, mean that the impact of any
misconduct on consumers can be devastating. How did we get to the point where banks
appear to have lost their commitment to their community obligations? The case of the
Commonwealth Bank of Australia (CBA) can help us answer this question because while all
the big banks came in for heavy criticism, it received a particularly damning assessment in
the Hayne Inquiry final report.

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 CBA Case

Commonwealth Bank

The Commonwealth Bank of Australia (CBA) is the largest of Australia’s ‘Big Four’ banks.
With its distinctive logo, a yellow diamond, with a black slice out of one corner representing
the stars of the Southern Cross, it is recognised as both the most valuable and strongest
brand in Australia. Prime Minister Andrew Fisher established CBA in December 1911. Its first
branch opened on Collins St, Melbourne in July 1912. For the first fifty or so years of its
operation, CBA was both a trading and savings bank but also Australia’s central bank. This
changed in 1960 when CBA passed central banking operations to the newly formed Reserve
Bank of Australia. In the 1970s banking in Australia diversified. CBA established its own
finance company and expanded into insurance and travel. By the 1980s, plastic debit and
credit cards entered the market with CBA, while the first automatic teller machine was
launched in 1981.

At the time of these new technological and business changes, the political and economic
landscape of Australia was changing. From the mid-1970s, deregulation began in the
Australian banking industry. The Final Report of the Campbell Committee of Inquiry into the
Australian Financial System, released in late 1981, facilitated several changes that aimed to
free up the financial services market. Deregulation meant there was a shift from regulating
financial activities directly to achieve monetary policy. Instead, after deregulation, banks
and other financial institutions had much greater freedom to respond to competitive market
signals and customer requirements, subject to meeting minimum prudential standards
designed to protect customers and maintain financial market stability.

Deregulation included actions such as floating the Australian dollar and allowing foreign
banks to enter the Australian market. Sixteen foreign banks commenced trading in Australia
from 1985, immediately doubling the number of banks operating. Competition in the
financial services industry became fierce.

In the 1990s a new threat to traditional banks appeared, as mortgage intermediaries such as
Aussie Home Loans and RAMS, life insurance companies and global financial services
companies all started to offer home loans and financial services at low rates. In 1990 CBA
merged with the State Bank of Victoria to become the largest bank in the country, leading
the market in retail banking operations. Between 1991 and 1996 deregulation of the
banking sector culminated in the privatisation of CBA, with the federal government offering
shares to the public. By 2018 CBA had the largest branch network in Australia with over 16
million customers and nearly 50,000 employees. Today it leads the market in home lending,
household deposits and credit cards and has over 830,000 shareholders.

Structurally, the role of the CBA board is to provide leadership and strategic guidance for
the organisation and delivery of its purpose. The key responsibilities of the Board are to: set
the strategic objectives and risk appetite of the bank, and lead the culture, values and
behaviours that deliver them; appoint the Bank’s Chief Executive Officer (CEO); and to
oversee the management, performance and corporate governance frameworks of the Bank.
In reality, the Board provides oversight and governance and it is the CEO and executives
within the organisation who maintain control over organisational practice. While the board

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 CBA Case

may approve policy, for example, the way these policies are interpreted and implemented is
the domain of the staff within the organisation. Part of the CEO’s role is to lead the culture
and balance it across different functions.

CBA's organisation is vast and complex. With both horizontal and vertical division of
resources along Business Unit and managerial lines. The Corporate Governance Framework
(Figure 3.) shows some of the managerial layers, but also the integration of policies,
processes, people and culture.

CEO

Corporate/Shared functions
IT, HR, CFO, Risk
Management, Corporate
Affairs

Institutional Banking & International Finanical

Retail Banking Services Buisness & Private Banking Wealth Management New Zealand (ASB)
Markets Services

Figure 2 & 3: Derived from Commonwealth Bank of Australia. (2019) 2018 Annual Report. Retrieved from
[Link]
[Link]

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 CBA Case

From tellers to sellers

How did the changes in the banking environment lead to changes at CBA? Looking back,
David Murray was CEO of CBA from 1993 to 2005 and oversaw many of the changes that
occurred due to financial deregulation and increased competition. The challenge faced by
CBA was ““How do we make sure that we put our customer in front of the right product
specialist at the right time? How do we get better at making and converting referrals in the
best interests of our customers?” These questions were influenced by the vast geographical
spread of CBA with many local differences and previously competitive business units. Intent
on increasing sales and cutting costs, Murray introduced the "Cohen Brown method" of
sales and service.

Cohen Brown Management Group, a corporate consultancy firm that focusses on delivery of
training solutions developed a front-line sales and service training system for the bank,
which aimed to increase the share of customer spend, market share, retention, and
customer satisfaction. The Cohen Brown method was ‘all-pervasive’; staff were encouraged
to spend more time with customers, cross-selling products and making referrals. Cohen
Brown called their program OneBankism, but CBA referred to it internally as OneTeam.

The program put CBA’s executive team at the forefront of cultural change and cascaded it
through the organisation rapidly. Roni Rutland CBA’s Executive Manager, Performance
Strategy at the time stated:

We said, let’s make sure our employees are fully aware that OneTeam is not just
another training initiative, but instead a profound strategic change led from the
top. So we took the essence of the Cohen Brown videos and re-shot them with
our own executive management team. That means that in
every OneTeam session, it is our own leaders who are voicing the principles
of OneTeam.

OneTeam cascaded from the top of the organisation, Phase 1-3 focussed on executive
general managers, or those who reported directly to the CEO and then their direct reports,
before rolling out to all front-line management and staff across the organisation. The key
principles in OneTeam involved ensuring that front-line staff had the right skills for
identifying customer needs and probing for opportunities outside their own lines of
business. Staff were also trained in a Cohen Brown customer needs analysis profiling
process. This involved asking probing questions to uncover customer needs, assessing those
needs and then delivering on them through referral to the relevant business units.

In addition to an organisation-wide training initiative, CBA business units created formal

agreements to outline how they would provide quality referrals to the proper specialists,
who were often in other areas or departments, and how they would handle referrals they
received to reflect well on the referring party. CBA’s 2007 Annual Report outlined one of
the key strategies:

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 CBA Case

The embedding of our Sales and Service culture has remained a priority. In
particular, we have placed emphasis on training our front-line people where
we have focused on disciplines around customer needs analysis, business
referral initiatives and taking ownership and following up…We have
introduced a new operating model into the retail branch network, giving our
branch managers greater autonomy, which will better meet the needs of our
customers and our people.

As part of the focus on sales and service front line staff had to attend meetings at the
beginning and end of each day. In these meetings employees were required to publicly
commit to the achievement of their daily targets. At the close of business, if they didn’t
achieve their defined targets some staff reported they were belittled or called out in front of
their peers.

During the 2000s, CBA closed branches and cut 3700 jobs, achieving savings of $1.5 billion.
While executive salaries increased for meeting cost-cutting targets, branch and call centre
staff faced increasingly challenging sales targets. Branch Manager Ann O’Farrell told BRW in
2004 "Every bank has customer service targets; they are part of business. But I would say in
the Commonwealth Bank they are being grossly misused. People in the bank think about the
targets, not the service.” Bonuses, typically paid once a year for the previous year’s
achievement of results, could far exceed base salary. The timing and size of bonuses
became an incentive, not just to remain with the organisation, but to potentially ‘game’ the
system. Some within CBA suggested that the relentless focus on sales and commissions
meant those such as financial planners - and senior management - were often at
loggerheads with the bank's compliance staff, who were there to make sure standards were
met.

In 2014 the Financial Services Union conducted interviews with over 800 CBA staff. National
Secretary Leon Carter said there was repeated evidence of workers suffering stress, with
more than half of the respondents saying they had to work overtime to achieve their
performance goals. In Queensland, a staff member said the falsifying of credit applications
was "widespread in our area". The staff member said they brought these issues to the
attention of management, who already knew about it. "Is this not fraud … Don't we get
dismissed for this conduct? No satisfactory answer was given."

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 CBA Case

Internal CBA research, overseen by the CEO, found that staff valued job security, career
advancement and a positive environment. People were “intrinsically motivated by feeling
that they are helping customers and playing their part in a winning team.” However, the
remuneration system, for both front line, managerial and executive staff, was built on the
premise of maximising money coming into the organisation.

In 2019, CBA strategy was outlined in their Annual Report (Figure 4), with an emphasis on
balancing outcomes for shareholders, customers, staff and the broader community. Not
everyone, however, was happy with the performance of the banking sector. Focus on
profitability and shareholder return was potentially driving behaviours that were not in line
with community expectations.

Figure 4: Commonwealth Bank of Australia. (2019) 2018 Annual Report. Retrieved from
[Link]
[Link]

While CBA data showed that customer satisfaction increased from 70.1% in 2008 to 84.2%
in 2015, some questioned whether the focus on customer satisfaction neglected attention
on dissatisfied customers. Further consideration of those with less positive experiences may
have highlighted ethical breaches that were occurring in the financial system. A 2019
University of Melbourne Report highlighted that one in three consumers were dissatisfied
with their financial institution, with trust being a major concern. According to this research
54% of consumers had issues with their financial service provider in the last five years.

Pressure began to mount in 2016-7 with media, consumer groups and members of
parliament making calls for a Royal Commission into the financial services industry. A
shortlist of just a few of the CBA transgressions identified by regulators and media in 2016-7
included:
 Outdated definitions of the term ‘heart attack’ used to avoid paying out life
insurance settlements and $100 million in fees charged for ‘no service’;

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 CBA Case

 A PwC report into home lending found problems with lack of verification of
borrowers’ financial circumstances;
 $10 million refunded to customers who were sold unsuitable credit card insurance;
 ‘Smart’ ATM machines that were used by criminals to launder millions of dollars - the
bank paid the largest civil penalty in Australian history;
 ASIC took the bank to court in January 2018 for ‘unconscionable conduct and market
manipulation’ over the bill swap rate (used by banks to settle debts with each other).

The Royal Commission into Misconduct in the Banking, Superannuation and Financial
Services Industry

On the 30th November 2017, Prime Minister Malcolm Turnbull announced the Royal
Commission into Misconduct in the Banking, Superannuation and Financial Services Industry
(the Royal Commission.) Lasting 12 months, with a budget of $75million, it was chaired by
former High Court Judge Kenneth Madison Hayne AC. Only two weeks after the
announcement Hayne wrote to sixty-one financial institutions, regulators and industry
associations (including CBA) asking them to describe any misconduct they had become
aware of over the previous decade and the steps they had undertaken to fix it. Over the
next 12 months, the Royal Commission conducted seven rounds of public hearings over 68
days, called more than 130 witnesses and reviewed over 10,000 public submissions.

One key issue presented to the Royal Commission concerned the practices surrounding the
sale of insurance products associated with financial services. Consumer credit insurance, or
CCI, at CBA came in three forms: credit cards, personal loans and home loans. During the
Royal Commission Clive van Horen, CBA’s Executive General Manager of Retail Products,
explained the selling of CCI products. Not only did staff have part of their salary aligned to
the achievement of performance targets, such as sales goals, but the organisation also
awarded different prizes for sales success. For example, a 2012 promotion awarded iPads,
iPhones, gift vouchers to staff for selling the most insurance over a specified period.

A 2011 ASIC report found that 20% of customers who purchased CCI had not 'actively
sought it out' – instead it was sold to them without their knowledge or consent. Staff often
used pressure tactics, harassment or ‘misleading representations’ to convince customers to
take out CCI. The Banking Royal Commission found that products were sold to
‘unsophisticated customers’, an example being insurance sold to a customer with an
intellectual disability.

In 2014 Matt Comyn, then head of retail banking, raised concerns with the CBA executive
team that these products were of ‘lower value’. A risk ‘deep dive’ by the bank in 2013 also
raised multiple concerns over these products. An internal CBA audit conducted in 2015
found 64,000 customers had been sold protection on their credit cards when they weren't
eligible to claim – primarily due to being unemployed or working below the minimum
number of hours the policies required at the time they bought the insurance.

In May 2015 Comyn had a meeting with Ian Narev, the CEO he would later succeed. Comyn
advised that more than 100,000 customers might have been sold insurance under false

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 CBA Case

pretences and presented a list of reasons why CCI products should be killed off within the
bank, including the fact they represented only $30 million in revenue (in an area that
generally turned over around $4 billion). Annabel Spring, the Head of Wealth, did not want
to cease selling these products. Both presented their argument to the CEO.

When testifying at the Royal Commission, Comyn discussed the outcomes of this meeting.
He had written in his notes “My recommendation to suspend the sales was not agreed
with.” Ms Rowena Orr QC questioned Comyn about his feelings on this:

Orr: What did you think of that outcome, Mr Comyn? You were head of retail
banking services at CBA. This was a product that you were responsible for. How
did you feel about agreeing to disagree with the CEO about your
recommendation that CBA cease the sale of the product?”

In his handwritten notes from the meeting, Comyn had written that the CEO had suggested
he “Temper your sense of justice." When asked for his interpretation of this note, Comyn
suggested it was linked to performance feedback he had received in the past suggesting that
he should “calm down.” CCI insurance continued to be sold by CBA from 2015 despite all the
reports and risks; however, when Comyn became CEO in 2018, the credit card insurance
product was withdrawn from the market. By 2018 CBA had agreed to refund $16million to
140,000 impacted customers.

Australian Prudential Regulation Authority investigates CBA’s culture

In May 2018 the Australian Prudential Regulation Authority, an independent statutory

authority that supervises institutions across banking, insurance and superannuation,
released the Final Report of the Prudential Inquiry into the Commonwealth Bank of Australia
(CBA). The Report found that CBA’s continued financial success dulled the organisation’s
senses to signals that might have otherwise alerted the Board and senior executives to a
deterioration in the company’s risk profile. In the Report they noted:

Even though all banks – especially large ones like CBA – require an extensive
network of formal rules and procedures through which to monitor and manage
their risks, these formal mechanisms are of themselves insufficient in ensuring
sound risk management. Ultimately, no Risk Appetite Statement, limit structure
or risk management system can anticipate or respond to every situation
effectively. Alongside the formal rules, banks must also pay attention to the way
these rules are interpreted and practised – that is, 'the way things are done
around here.' These practices form part of the cultural norms of a bank.

APRA highlighted that financial institutions require a sound risk culture, consistent with
strategy and embedded across different parts of the business. An influential, positive culture
has strong leaders role modelling behaviours, constructive challenging of poor practice
without fear or blame, and timely information flows all underpinned by a strong risk
management framework. A sound risk culture is evident through rewarding right
behaviours and penalising those who do not act in accordance with the norms inherent in
the culture.

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 CBA Case

At the senior level of the bank, APRA highlighted a lack of collective ownership of risk
management. With individual leaders focusing on accountability in their own areas, the
drive for organisational-wide interest and challenge was reduced. The Report also
highlighted that leaders failed to 'walk the talk' when it came to managing risks in the
organisation, that is CBA's leaders had not all consistently practised what they preached.
Specifically, leaders had been observed to communicate the importance of values, but not
necessarily act accordingly. APRA recognised that a sound risk culture would require all
leaders and employees to role model appropriate behaviours and action (not just
awareness), supported by practices that were well embedded in the organisation.

On a positive note, APRA recognised that CBA had a highly collegiate culture where people
collaborated across roles and business units. This is important for an organisation divided
into structured Business Units that are offering different products or targeting different
consumers. Before 2011, the bank had much more internal competition and a more
combative environment leading to entrenched departmental divisions or silos. CEO Ian
Narev, who commenced in 2011, helped shift the culture in CBA to one that valued
collegiality, collaboration and trust.

APRA noted, however, that there was a dark side to the cultural shift that occurred in CBA
from 2011. A collegial environment had led to over-confidence and misplaced confidence in
the abilities and decisions of people in CBA, including its leaders. At the same time the
desire to move beyond competitiveness or combativeness led to pockets of excessive
consultation or consensus-driven activity, slower decision making, lengthier processes and
slippage of focus on outcomes. Evidence showed a reluctance to challenge authority or
question colleagues’ actions or behaviours across CBA, including at the Executive Committee
and Board level. Executives were less likely to raise concerns outside their own area or
department, especially if previous attempts to raise issues were seen to be unsuccessful.
The report recommended that the bank should engage in cultural change to move from
“complacent to empowered, challenging and striving for best practice in risk identification
and remediation” and that there needed to be an “injection into CBA’s DNA of the "should
we" question in relation to all dealings with and decisions on customers”.

Upon the release of the APRA report, then CEO Matt Comyn emailed copies to 500 bank
executives who were asked to discuss the report with their teams and supply a one-page
reflection on that discussion. One senior executive, Marianne Perkovic wrote, “I know I
have let some of our clients, our people and the community down by not speaking up loud
enough to stand up to behaviours that I knew were not right.” A manager in the compliance
department, Larissa Shafir, wrote suggesting that her department was lacking in authority
and was seen by others in the business as a ‘blocker’ to success. CBA began to engage in
conversations that examined the relationship between corporate strategies, managerial
policy and behaviours and the bank’s role within the community.

Banking Reforms and the future

It is the role of the bank’s Board to make a judgement about the implications of
remuneration policies and whether they are acceptable to the bank based on current social

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 CBA Case

norms. In 2016, despite the increasing number of payouts, fines, investigations and
scandals, then CEO Ian Narev could find no reason that executives in CBA should not receive
their full allocation of bonuses. The Board accepted the remuneration committee’s
recommendation that Narev himself receive 108% of his bonus, or $2.862 million in addition
to his $12 million annual salary. Documents to be included in the Royal Commission showed
that in a period of the worst fines and scandals in Australia’s banking history, no CBA
executive lost a cent of their bonus in seven years. At the Annual Board meeting the
shareholders were not impressed. Shareholders protested, making a 'strike' against the
remuneration report, the largest vote against pay packets recorded in corporate Australia.

Ian Narev and CBA agreed to bring forward his retirement. Matt Comyn, who was head of
Retail Bank when much of the misconduct occurred, was appointed the next CEO
commencing April 2018. When asked what sort of message this sent, to the CBA staff and
the broader community, to promote the person who was in charge of the division in which
all these issues arose, the chairman responded, “The easy answer for us would have been to
appoint an external person. To find an external person globally at a level who has not been
involved in some regulatory event is impossible.”

The Hayne Report made a number of explicit recommendations about governance, culture
and remuneration practices within the financial sector. Specifically:

 Financial services entities should design their remuneration systems to encourage

sound management of non-financial risks, and to reduce the risk of misconduct;
 Financial services entities should make regular assessments of the effectiveness of
the remuneration system in encouraging sound management of non-financial risks,
and reducing the risk of misconduct;
 Financial services entities should set limits on the use of financial metrics in
connection with long-term variable remuneration;
 All financial services entities should review at least once a year the design and
implementation of their remuneration systems for frontline staff;
 All financial services entities should, as often as possible, review their own culture
and its governance, identify and deal with any problems identified and determine
whether the changes made have been effective.

Directly responding to the Hayne recommendations, CBA stated in March 2019 that “we
have made enhancements to remuneration to place greater emphasis on not only the
balance of outcomes to be achieved by our people , but also the manner in which they are
achieved.” In a further response by CBA to the APRA Prudential Report, they argued they
would be making a number of changes to their organisation and culture:

The APRA report is clear - our culture needs to change to be less complacent and
reactive, more accountable and more open to challenge. Leaders will be expected
to understand customers better and to listen to them. They’ll need to have a
genuine appetite to learn and to improve how they are performing.

Leaders will also need to show that they reflect carefully on what they are doing,
instead of just managing the day to day, and constructively challenge their

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 CBA Case

colleagues instead of going along with the status quo. They’ll also need to
demonstrate a crystal-clear understanding of what they’re accountable for.

Matt Comyn describes his influence over culture, since becoming CEO as “What I role model,
what I reward, where I allocate consequences, who I hire, who I fire, who we promote inside
the organisation.” While on the stand during the Royal Commission, Comyn was challenged
on cultural change by senior counsel assisting the commission, Ms Rowena Orr QC:

ORR: What, in your mind, is the single most important thing for you to do personally to
change the culture within your organisation?
COMYN: To pick the right people.
ORR: To pick the right people?
COMYN: Yes
ORR: That’s the most important thing?
COMYN: Yes.
ORR: Yes. And do you feel that CBA has had the right leaders in the past?
COMYN: No.
ORR: Do you feel that they have the right leaders now?
COMYN: We will see. I hope so. Yes.

This case has been prepared by Dr. Kim Goodwin (Department of Management & Marketing,
University of Melbourne) based on published sources. This case study is for teaching
purposes in Organisational Behaviour (MGMT200001) only and must not be distributed
without permission of the author.

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 CBA Case

APPENDIX ONE: Selected CBA timeline

2011
Ian Narev
1990s becomes CEO.
Mid 1970s Mortgage Cultural shift 2018 CEO Ian Narev
Deregulation of intermediaries 1996 toward APRA Prudential resigns and Matt
1911 the banking enter Australian CBA fully collegiality and Report into CBA Comyn appointed
CBA Founded market begins market privatised collaboration released new CEO

1960 1985 1993 David 2000s 2017 2018

Central bank Foreign banks Murray becomes "Which New The Royal Banking Royal
functions enter Australian CEO. Introduction Bank" program Commission into Commission
tranfered to market of the 'Cohen closes branches Misconduct in Interim Report
newly established Brown Method' and clashes staff the Banking, released
Reserve Bank of Superannuation
Australia and Financial
Servec Industy
begins

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 CBA Case

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Battellino, R. (2007). Australia's Experience with Financial Deregulation. Retrieved from
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 CBA Case

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