Accountability starts with keeping track of conflicts of interest. Fail to do that, and corruption comes next. As the Matt Hancock saga shows all too clearly.
Back in my banking days, part of my job – frankly, one of the less fun parts – was to help people understand not only what restrictions and controls applied to what they did, but why.
This was always, to my mind, critical. People might not agree with the “why”. Often, they didn’t. But you owe it to them to explain them. There’s a reason why “Because those are the rules” is on a list of “Things never to say to anyone, ever” in one of the most helpful books on interpersonal communication I ever read.*
Often I could understand people’s questions. Not least because banking systems and controls frequently appeared to be designed by people who’d never, actually, met people before. Which broke Scott-Joynt’s First Rule of Policies and Procedures: don’t ever expect human beings not to behave like human beings; so design your systems with the grain of how people tick.
(The second rule, of course, is that policies are either written for people to use, or written to cover the organisation’s backside. Those written for the first purpose can often also achieve the second. Those written for the second, usually by lawyers like me, can never achieve the first. This is also the difference between focusing on risk and focusing on compliance; but that’s another discussion.)
But one set of questions always baffled me: those about conflicts of interest, and why they needed to be declared. Banker after angry banker would wave the form at me demanding why on earth the bank needed to know about the relationships they had and the businesses they were connected to. “None of this is relevant,” they’d grouch. “I haven’t done anything wrong.”
They were probably right. And it didn’t matter. Because the whole point of conflicts checks and declarations – whether general ones, or requirements to declare an interest if you’re involved in a decision which could benefit someone or something close to you – is preventative, not detective. It’s to put transparency in place before it’s needed, so that conflicts never actually arise. Which is why the broad declarations are needed: to avoid situations where there might appear to be a conflict, and thus the risk – yes, you guessed it – of corruption.
It doesn’t work that way, of course. People don’t declare. Often it’s relatively innocent, in a way: people think they’re not the kind of person who’d act improperly, to act partially, so therefore they don’t need to declare anything. Only dishonest people need to do that. And they’re not.
Balderdash. Most of us have immense blind spots when it comes to favouring those in our circle. Because we’re human. Because that’s how humans tick. So it’s not a matter of trusting honesty. It’s a matter of building in solutions where problems might arise, shining a great big spotlight on them, verifying connections, and thus obviating the problem as far as possible.
Why has this sprung to mind? It’s fairly obvious, I think: the Hancock Half-Hour of shame. The embarrassing clinch and the shameful do-as-I-say, not-as-I-do in re social distancing regulations and guidance is bad enough. Certainly enough reason for anyone with the slightest integrity to have resigned instantly, or (when it comes to his boss) to have sacked him on the spot. As is the hypocrisy of having demanded the head of Neil Ferguson, and then going on to do even worse yourself.
But the conflicts are to my mind far more serious. There’s the obvious one, and the less obvious one.
- The first: the fact that Hancock appears to have given a job to a woman he was having an affair with, in secret, as well as sending work to members of her family. All while – so it’s reported – keeping comms relevant to this kind of thing out of government systems and on a private Gmail account. When the job or the contract came up, the only ethical thing to do would have been to declare an interest. He didn’t. Draw your own conclusions.
- The second: the fact that the only person with the power to decide whether his actions were acceptable or not is the PM. Someone not only with ethics that make Hancock look honourable, but with an immense vested interest in the outcome.
Conflicts matter. Because being accountable matters. (Not just paper accountability; real accountability, in the sense of submission to those whose interests are not aligned with yours, and who have authority separate from your own.) Because transparency matters. And without it, you have corruption, self-dealing and disgrace.
*The book’s called “Verbal Judo”. Setting aside the unfortunate fact that the co-(ghost?) writer seems to be the bloke who later co-wrote the ghastly “Left Behind” series of apocalyptic cod-Christian guff, it’s excellent. Written from a police officer’s point of view, but with much wider application. If I mention that other phrases on that list include “you always/you never”, “come here”, “be reasonable”, and my personal favourite, “calm down”, I hope you’ll agree there’s some smart and thoughtful stuff there.
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