Grey matters ethical dilemma: Remotely challenging

A junior manager faces a tough decision when his boss pressures him to bend the rules to speed up completion of a report. What should he do?


Satish is an ambitious junior manager in the certifications team of a regulated wealth management firm. The firm experienced a difficult period some years ago, when it struggled to keep up with a greatly increased flow of regulatory reporting, the consequences of which led to adverse comments and warning of potential sanction by the regulator.

As a result of these regulatory findings, the firm had recruited more staff but, given the pandemic, a number of people have been put on furlough, the majority of staff are working from home and there seems to be a growing trend within the company to make decisions in isolation. There is more work to do with fewer people and some managers are taking an ‘out of sight, out of mind’ attitude by reducing interactions with their teams on a day-to-day basis.

Satish, however, is conscientious and knows that the new certifications reporting process is very important. One of the biggest changes is the introduction of an internal reporting system, which is seen as increasingly onerous and somewhat irrelevant by those not involved in the firm’s earlier problems. As a result, the requirement for an esignature by nominated position holders is not always followed to the letter.

Eamonn suggests that Satish should sign the report on Eamonn's behalfApproaching the new reporting deadline, Satish is asked by Eamonn, his manager, to ensure that the new departmental management information (MI), which Satish coordinates and analyses, is up to date for discussion at the heads of division meeting, which is taking place on Zoom. Bearing in mind the previous and well-documented difficulties of his team, Eamonn will likely be the focus of attention as he will need to give an update on the new regulatory reporting process to the Board.

Satish is feeling under some pressure, especially with the reduced headcount, and is working longer hours at home, including time at the weekends. He is determined to meet all his deadlines, conscious that his chances of promotion will be influenced by how well he performs at times like this, and fearful that he may be let go by the company if he doesn’t, given the economic environment.

The end of the reporting period approaches and Eamonn begins to press Satish for the MI in their online daily meetings. The firm’s regulatory reporting unit also reminds Satish that his department’s report is due and that it needs to be signed off by Eamonn.

As his deadlines loom, Satish calls Eamonn and shares the MI report on screen, taking the opportunity to remind him to officially sign off the department’s regulatory report, which will be ready the next day. Sounding exasperated, Eamonn says that he is too busy preparing for his meeting to be concerned about “that sort of stuff” and suggests to Satish that, if he is confident that it is correct, he should sign it on Eamonn’s behalf. The firm’s strict guidelines on the sign-off process stipulate that this can only be done by Eamonn, but Satish feels unable to say anything.

The following day, his department’s regulatory report is completed and sent to Satish to obtain Eamonn’s signature. Satish tells his colleague that he will see whether he can get Eamonn to esign it, but he is extremely busy, and the meeting is soon.

Satish calls Eamonn to ask him to sign the report. “I told you yesterday that you could sign it” says Eamonn. “It’s only a report and you know what it is all about. You have my complete confidence – so take some personal responsibility.”

Readers selected one of the following options in response to the question of what Satish should do next (voting is now closed):

  1. Sign the report, keeping Eamonn happy. He will be knowingly breaching company rules, but as this is the first time, he hopes for the best.
  2. Insist that Eamonn sign the report. The report will be late, and the department will look bad once again. This may affect his chances of a promotion and possibly even his job.
  3. Ask another manager to sign off the report. It will make Eamonn look bad, but Satish is pressed for time.
  4. Explain to the regulatory reporting unit why Eamonn’s signature is missing, saying that Eamonn authorised him to sign the report.

This dilemma appears in the February 2021 flipbook edition of The Review magazine. The CISI's opinion and voting results will be published in the May 2021 edition
Published: 10 Feb 2021
  • Compliance
  • Risk
  • Wealth Management
  • Training, Competence and Culture
  • Integrity & Ethics
  • working from home
  • reporting
  • grey matters ethical dilemma
  • furlough
  • Covid-19
  • Code of Conduct

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