March 29, 2023
Feeling excited and truly honoured that the United Nations University Centre for Policy Research (UNU-CPR) has published the report undertaken through the Finance Against Slavery and Trafficking (FAST) project in UNU-CPR.
The published report:

  1. Analyses publicly available National Risk Assessments (NRAs) from sub-Saharan African countries and provides a view that explains how these NRAs analyse modern slavery and human trafficking (MS/HT) risks.
  2. Considers the extent to which AML measures (for example, SARs, financial investigations, supervisory and regulatory activities, asset freezes, and use of targeted financial sanctions) have been used in practice in sub-Saharan African countries to address MS/HT.
  3. Provides recommendations for consideration by governments, financial intelligence units, relevant regulatory agencies, law enforcement agencies and financial institutions.
    I hope this work contributes meaningfully to the dialogue to strengthen AML measures to combat modern slavery and human trafficking.

January 25, 2023
A friend recently went to see a doctor about a problem with their middle ear. A day later, there were ad emails on hearing aids. Another person was talking privately to an advisor about estate planning, only to be bombarded by unsolicited ads for life policies or funeral cover.
This is one of many stories about unsolicited adverts that somehow ‘mysteriously’ appear, linked to a similar or related topic a person was contemplating. The application of algorithms has many positive use cases, and allows for tailor made offerings to anticipate and suit individual customer needs. However, within the context of data privacy and protection, the ethics around the use of data fed into algorithms needs closer scrutiny.
For businesses using algorithmic models that consume private and personal data for current and prospective customers, there is an ethical and legal responsibility to understand the source of data ingested, and whether there is informed customer consent, legal or contractual justification for the utilisation and processing of such data.
It is said that for 21st century business models, data is the new currency. Responsible businesses embrace this change whilst respecting entrenched personal liberties. They establish governance frameworks and effective risk management strategies around the sources of data, data relevance, data quality, design of algorithms, their development, deployment and validation of outputs. Technology and digitisation must be applied ethically to support human and enterprise advancement and not in a way that violates privacy and the right to personal integrity.

December 7, 2022
‘We never saw it coming’

Books and media reports are full of stories of investors, directors, leaders and many others who were blindsided and caught unaware about corporate and governance failures in their backyards. One culprit at the heart of many such failures is information asymmetry. When there is a distortion of information by a party and the storyline is either understated or overstated in such a way that the quality of information is twisted, there is an increased risk of misreading the facts and consequently, impaired decision making.

A healthy system of checks and balances across 1st, 2nd and 3rd lines of defence is necessary. When only good news stories are welcomed, whilst objective and independent voices are muffled and not encouraged — this is often a recipe for great disappointment and embarrassment.

Words of wisdom : Trust and then verify…

November 30, 2022
When talking to a number of business leaders and entrepreneurs about ethics, conduct and compliance risk, the notion of pragmatic realism keeps coming up.
The question is: what is pragmatic realism in our context? Pragmatic realism challenges us to reassess practices and exercises that no longer hold relevance or do not add meaningful value. It is not viewing the world through a paradigm of abstract theories that are removed from day to day life and business realities.
It requires us to acknowledge that in an ecosystem designed and managed by people, it will not always be 100% perfect. Yet, it is not an open cheque book to go with the flow and continue with uncompetitive practices, market collusion, product misselling, pushing defective products, delivering subpar customer service, poor customer outcomes and paying or taking bribes merely because others are doing it.
It entails looking realistically at the operating context and embracing innovation, new methods, frameworks and ways of thinking and finding solutions to problems.

September 28, 2022
Someone recently asked me: “What does ‘doing what is right’ mean to you?”

To me it means acting with integrity and being honest in dealings. It does not mean perfection or not making mistakes but rather owning up for mistakes made and to learn from them. It means willingness to be held accountable for actions taken and being decisive whilst showing empathy. It calls for courage to own your voice and to stand for your principles and values. It also requires listening in order to understand the purposes, concerns and circumstances of others. Ultimately, it is about avoiding and mitigating against causing undue harm and not turning a blind eye to blatant injustice or wrongdoing. It is about about fairness, equity and doing what is just.
What does doing the right thing mean to you?

August 10, 2022
As consumers pull back on spending due to rising inflation, some businesses are ramping up efforts to stimulate demand and retain customers.
Recently I received a call from an institution that has a customer loyalty program that is intended to incentivise and reward customers for taking multiple products and solutions with the same institution. On the face of it the loyalty/reward program sounded great and seemed to be giving value back to customers. However, on close scrutiny the program was actually very complex and was underutilised by many customers because it required someone well-acquainted with the product design in order to unlock the full benefits as marketed.
The main objective in some customer loyalty schemes is ‘up selling’ own products and solutions but there are high and unrealistic hurdles introduced for customers to redeem or access full rewards. Businesses that embrace a shared value mindset foster a culture and mindset where the interests of the customer are placed at the heart of business strategy and product development.
Transparency and disclosure of information – in a manner and language that customers can understand – whilst lifting undue and unreasonable barriers to accessing benefits, are foundational to fair customer treatment.

July 6, 2022
If we operated in volatile , uncertain , complex and ambiguous ( VUCA) times before, the past 2.5 years have certainly lifted the bar to more dizzy heights.

​The world around us presents new opportunities but it is also unpredictable and in a state of constant flux. Just as we are trying to lift our heads from the Covid-19 tidal wave, there is war; extreme weather conditions; global supply chain challenges; political tensions and rising inflation which are increasing operating environment pressures. Regulatory arbitrage; unfair customer treatment; bribery and corruption; money laundering; sanctions and moral hazard are just some of the elevated risks in the current environment. In these complex operating conditions, pressure to perform can increase the temptation to cut corners, bend the rules and to ‘wink and nod’ at ethically undesirable practices in order to get things done.

Organisations that are dedicated to embedding a culture of doing the right thing, are ‘situation-aware’ and cognisant of their changing operational context. They retain a shared value mindset even as they navigate crisis situations and are intentional about not compromising the future for short term gain. They are nimble , adaptable and apply innovative solutions to drive efficiency and to answer complex questions whilst putting in place well considered proactive steps to mitigate against these emerging risks.

Rapid change demands ethical and visionary leadership to navigate the ship. Profit and revenue growth are important but should not reign sovereign over safety, human rights and due regard for social well-being.

June 22, 2022
Ethical culture needs commitment across multiple levels across the organisation.
Whilst the top sets the tone, the middle sets the mood and tempo which plays out in the rhythm on the floor. Exemplary leadership demands that those at the top must move beyond politically correct statements, ‘walk the talk’ and live out the professed values. The middle is where the rubber hits the road and it represents the day to day lived experience of many. A capable and empowered middle management models the right behavior whilst navigating complexity. Capable managers and leaders do not lead through fear but embrace critical thinking, open dialogue and an attitude of doing the right thing. A wise leader with insight does not foster, nurture or protect wrongdoing and unethical conduct but is courageous enough to confront and call out those who do not act and live according to the organizations values.
​Where misconduct, unethical conduct and corruption are observed but ignored or not decisively acted upon, this breeds impunity where some people feel ‘protected’ to continue on their corrosive path with the knowledge that there will not be any meaningful form of accountability.

May 11, 2022
Effective internal challenge and a culture of honest and open conversations are essential elements of prudent risk management.

Organizations that are serious about creating an ethical culture are deliberate about building a safe environment where employees have psychological safety to speak up. They create a climate where employees and other stakeholders have access to safe , secure and efficient resources and channels they trust to raise issues. At times organizations lose the opportunity to lead the conversation, do the ‘right thing’ and ‘self-cleanse’ when misconduct is covered up and there is a ‘conspiracy of silence’. Fear of reprisal, retaliation, being sidelined or ostracised can become barriers for building an ethical culture that embraces accountability.

April 6, 2022
The 2021 Global Business Ethics Survey revealed that ‘the stronger the culture, the greater the impact of ethics and compliance programs, and the higher the quality of the program, the stronger the ethics culture’. Therefore, a solid ethical culture is the bedrock of effective high quality compliance initiatives. However, measuring ethical risk culture cannot be done using a single lens of ethics program adequacy but rather through a multidimensional view. An interpretation of multiple data sets to form a comprehensive view about the true state of play is essential.

March 29, 2022
Culture is more than just spoken and written words. It lives through unspoken words and in behaviours observed. It is present in silence, in conduct and in actions. It permeates through what organisations permit or tolerate; what organisations reward and what organisations sanction either through action, inaction or omission.