Editor’s note: In May 2017, Theresa LaPlaca was named the head of the new Conduct Management Office, formerly known as the Office of Ethics, Oversight and Integrity, after serving in an interim capacity since January 2017. She shares what her new team has been working on, what team members can expect going forward, and how she views the progress on building a better, stronger bank.
Q: What is the purpose of the Conduct Management Office?
The Conduct Management Office’s mandate is to manage conduct risk and drive consistency in the way Wells Fargo receives, researches, resolves, and oversees allegations and customer complaints. We designed the office to create a strong, independent organization with visibility across the enterprise. The office includes the newly merged Ethics Oversight, Sales Practices Oversight, Internal Investigations, and Complaints Oversight groups, as well as reporting and administrative functions.
We are hard at work to make sure that team members feel comfortable raising concerns and know that prompt investigation and appropriate action will be taken when they identify an issue that puts our company or customers at risk. With the creation of the Conduct Management Office, we can more effectively manage complaints, allegations, and investigations in a consistent and efficient way. The Conduct Management Office has full authority to assess issues across the organization, advise business leaders and ensure that changes are made that adhere to our policies and procedures, and escalate any issues to the CEO as well as the Risk Committee of the Board of Directors.
Q: What is the Conduct Management Office’s priority work?
We need an infrastructure that supports strong, long-term conduct management that addresses the needs of our many stakeholders. Team members across the company need to feel safe raising concerns; regulators require regular reporting on the progress we are making; and the Board of Directors needs insight into complaints and allegations so they have confidence that issues are being addressed and trends are being identified early so that we can address risks before they become issues. This is why we’re building a single system that allows us to track team member allegations from intake to resolution, with multiple touchpoints with the team member along the way.
Q: Why are you the right person to be the permanent head of the Conduct Management Office?
I care for each and every team member in this company — my goal is for the Conduct Management Office to ensure that team members and customer concerns are being appropriately addressed. I also want to get things done quickly and correctly. I’m moving fast, but not without making sure that we’re doing things the right way. Sometimes that requires me to be strong and direct, which I’m OK with — when it comes to integrity, you can’t waver.
I’ve worked for Citigroup and Lockheed Martin, and was a teller and branch manager at the beginning of my career. I bring all of that diverse background and experience to this role. I am humbled by this opportunity, honored to do it, and committed to leading the team to be the best it can be.
Q: What would you tell team members who don’t feel safe raising concerns with managers or using the EthicsLine, or who have a fear of retaliation?
It’s important to me, not only as a team member but as a stakeholder, to make sure that we do what’s right for our company and team members. We have created new policies and are making improvements to the process for managing team member concerns.
We now have an Allegation Management Policy that addresses confidentiality and consistency and sets the standards and procedures for all intake channels, which means everyone is caring for concerns the same way. The policy includes requirements to enhance process quality and oversight and identify and address the root causes of reported issues.
We also have the new Speak up and Nonretaliation Policy that sets expectations for all team members to raise concerns and for managers to help them feel safe and supported when they do. We have zero tolerance for retaliation against team members for reporting suspected ethical issues, and anyone found to have retaliated will be subject to appropriate corrective action.
We have also made progress in improving how team member concerns are being managed, including a new dedicated Employee Relations team focused on issues raised through the EthicsLine; a new process for third-party legal review of retaliation claims; standard protocols across research and investigative teams to ensure consistency; and updated messaging and website enhancements with the EthicsLine vendor. Additionally, we’re creating a new EthicsLine website to make it easier for team members to submit a report online at their convenience.
Q: What has been the most challenging part since you began this role in January?
There is still a lot of work to be done — it takes a lot of coordination to do it right and bring the team and the company together. It’s all happening in real time, and we need to continue moving fast until we get this work to a place where it’s business as usual and then continue to make enhancements. I am confident that our team will deliver and team members will feel safe and supported.
Q: What are you most excited about going forward?
I have a great team, and we have the support of the company behind us. We have the support of our Board of Directors, and that’s empowering. We’re creating a lot of changes in infrastructure, process, and oversight, and knowing that our executives are in full support of these changes makes me excited about the positive impact all of this work will have on our team members, too.
Q: What is different today than a year ago?
We are better aligned to build a strong program and are a unified front, from our executives to team members across the company. We all have a stake in this and are working together, listening to one another, supporting one another, and holding one another accountable. Team members are talking, and I think everyone is really listening — listening to what the problems are, where team members are struggling, and the suggestions team members are offering. It’s a good place for our company to be as we work to build a better Wells Fargo.
Q: What has been accomplished in the last six months, and what can team members expect from your office in the next six months?
We’ve been setting up the office, bringing groups together in the Conduct Management Office, hiring the new leaders, developing and implementing our conduct risk framework, and building an efficient front-end system that compiles information in one location and makes it easier to analyze the data. We’ve put together metrics and developed cohesive reporting so we can see both team member allegations and customer complaints.
In the next six months, I want team members to truly feel like they have a better experience if or when they use the EthicsLine. Our policies will ensure that all team members are treated with care and confidentiality.
We’re also working to help managers create a safe environment and respond appropriately when a team member raises a concern. The annual Code of Ethics training now includes an activity for managers on making team members feel safe when raising concerns, which will be reinforced through guided discussions among local leadership teams. This training will ensure that all managers know what’s expected and begin talking openly about ethics — a suggestion that came from a team member.