Banking code of Practice, a document that some banks claim to adhere to, but it’s hidden in plain sight.
When reading these statements from a bank’s code of conduct or customer service principles, banks define key terms in ways that ensure legal compliance and operational efficiency.
Definition of “Code”
The “American Heritage Dictionary of the English Language, 5th Edition”, defines “CODE” as
“A system of symbols, letters, or words given certain arbitrary meanings, used for transmitting messages requiring secrecy or brevity.”
There you have it, “Banking Code“, hidden in plain sight. Does this mean banks have their own (secret) definitions of words?.
Here’s a breakdown of how some key key terms (like trust, confidence, integrity, etc.) might be interpreted from the bank’s perspective, compared to how most consumers would understand them:
1. Trust and Confidence
Bank’s Definition:
- “We are committed to earning and retaining the trust of our customers and the community.”
In the bank’s terms, trust likely refers to their ability to follow financial regulations, protect customer deposits, and comply with legal requirements.
This could mean they focus on their competence as a financial institution, rather than focusing on the personal or ethical aspects of their relationships with individual customers.
- “We are committed to making promises and keeping them to deliver good customer and community outcomes.”
This likely means the bank aims to fulfill contractual obligations and regulations (such as loan terms, fees, and interest rates).
From their perspective, keeping promises means adhering to written agreements or contractual terms rather than necessarily acting in a fair or customer-first manner. The “outcomes” they deliver might also prioritize profit generation over customer satisfaction.
- “We will comply with all laws relating to banking services.”
This statement focuses on legal compliance—the bank will act in accordance with the law. However, it doesn’t necessarily imply fairness or honesty beyond legal requirements.
Essentially, the bank’s definition of trust is about being legally trustworthy, not necessarily being ethically trustworthy.
2. Integrity
- Bank’s Definition:
“We will act honestly and with integrity.”
Here, honestly and with integrity could be interpreted as complying with regulations and financial codes of conduct. However, integrity might not always align with ethical behavior in the broader sense.
It could be limited to business integrity in terms of financial operations (e.g., keeping financial records correct, following tax laws, or ensuring compliance with lending standards).
In reality, honesty could mean the bank is truthful within the context of their contracts, but it doesn’t necessarily mean they will always act in the customer’s best interest.
“We will be fair and responsible in our dealings with you.”
Fairness here is likely referring to following guidelines and policies—not necessarily treating customers equally or ethically. For example, they may apply standard fees to everyone or follow internal procedures, but fairness doesn’t mean transparent or above reproach in all cases.
They may claim to be responsible, but that responsibility may only go as far as legal compliance, not customer benefit.
3. Service
Bank’s Definition:
- “We will deliver high customer service and standards.”
The bank’s high standards likely refer to their internal performance metrics (e.g., processing times, customer response rates, or service availability).
Customer service could mean they aim to meet operational goals like minimizing wait times or ensuring their services are available. But these standards may not necessarily be focused on personalized care or ethical customer treatment.
- “We will ensure banking services are accessible, inclusive and provided to you in a fair and ethical manner.”
Inclusive and accessible may focus on the availability of services (i.e., online banking, ATMs, etc.) and making sure customers are legally allowed to access services.
However, fair and ethical manner could be interpreted as fairness in policy application (e.g., consistent lending practices). Not acting in an ethically responsible way (e.g., ensuring the customer is treated fairly in all aspects of their financial well-being).
So, this doesn’t imply that all customers will be treated equally or that unfair practices won’t occur—just that the services are available and compliant.
4. Transparency and Accountability
Bank’s Definition:
- “We will communicate with you in a clear and timely manner.”
Clear and timely communication could mean that the bank will send statements on time, provide contractual terms when requested, and notify customers of changes to services or fees.
However, it doesn’t necessarily mean full transparency about all internal operations, fees, or practices. They might communicate, but they may also obfuscate or hide details within complex documents or small print.
- “We will be accountable in our dealings with you.”
Accountability according to the Banking Code might be about taking responsibility for actions when complaints arise. But it could also mean the bank will defend its position in any legal or regulatory issues.
It doesn’t necessarily mean the bank will admit to mistakes or correct actions in the interest of the customer. Just that the bank will respond to issues as required by law or policy.
- “We will be transparent in our communications with you.”
Transparency might mean the bank will disclose information required by law. But it doesn’t necessarily mean they will provide full disclosure on all terms. Especially those that could be to their disadvantage (such as hidden fees or excessive charges).
The bank could be transparent in terms of its regulatory obligations. But not necessarily honest or clear in ways that benefit the customer directly.
And that, it seems, is the same with the information published in the Banking Code of Practice.
Translation of Banking Code
Trust and Confidence = Legal reliability and compliance, rather than personal or ethical trust.
Integrity = Adherence to legal standards, but not necessarily ethical behavior in all cases.
Service = Standardized customer interactions based on operational goals, rather than personalized or ethical service.
Transparency and Accountability = Legal and regulatory transparency. Not necessarily openness about internal practices or decisions that might harm the customer.
Banking Code Key Takeaways
While the bank’s code of conduct emphasizes terms like trust, integrity, and transparency, the actual application is dubious.
For banks, these terms are often used to indicate legal compliance, risk management, and business operations. Not the more personal, ethical, and transparent understandings most people have of these words.
The bank’s definitions focus more on following the letter of the law, keeping records clean, and protecting their financial interests.
But consumer trust, honesty, and ethical treatment of customers might be secondary or only partially addressed in the banking code.
Admit nothing. Deny everything.
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