Sanusi Lamido Sanusi: The Nigerian banking industry - what went
wrong and the way forward
Text of the Convocation Lecture by Mr Sanusi Lamido Sanusi, Governor of the Central Bank
of Nigeria, to mark the Annual Convocation Ceremony of Bayero University, Bayero
University, Kano, 26 February 2010.
* * *
1. Protocols
May I begin by thanking the Vice-Chancellor, the Senate and Congregation of this great
university for the honour of inviting me to deliver this year's convocation lecture. I am not a
graduate of this esteemed institution but my links to it are indeed very deep. On a purely
personal level, this university is named after my great grandfather and I take personal pride
in being the first among his descendants to stand here and deliver an academic paper. But
also, and this may not be known to many of you, some of the earliest professors of this
university including a former Provost are my maternal uncles and great uncles. I am proud to
count among my mother's uncles some of the professors associated with this university from
its earliest days, such as Professor Shehu Galadanci (Arabic) and the late Professor
Muhammad Kabir Galadanci (Hausa), and besides them countless uncles and cousins on
the academic staff. While I did my own stint as an academic in the economics department of
ABU Zaria in the early 80's, I am most proud that my younger brother, Abubakar, Wambai
Sanusi is on the academic staff of the economics department of BUK. But this is not all. The
2010 convocation comes with other unplanned joys. In addition to honouring me with the
opportunity to take the podium today, the University will tomorrow honour my great-uncle, an
illustrious son of this city, AVM Nura Imam (rtd,) with a doctorate degree. And before you
think I am through, my immediate younger sister, Zainab Sanusi, is one of the students
receiving a Master's degree tomorrow. This could not have been planned better. For all these
reasons, and for the many friends and academic colleagues here, this feels truly like a
homecoming and I do pray it will be a successful one.
As you all are aware, the world economy was hit by an unprecedented financial and
economic crisis in 2007-2009, tipped into recession by the subprime crisis in the US in
August 2007. This crisis led to the collapse of many world renowned financial institutions and
even caused an entire nation to be rendered bankrupt.
In Nigeria, the economy faltered and the banking system experienced a crisis in 2009,
triggered by global events. The stock market collapsed by 70% in 2008-2009 and many
Nigerian banks had to be rescued. In order to stabilize the system and return confidence to
the markets and investors, the CBN injected N620bn of liquidity into the banking sector and
replaced the leadership at 8 Nigerian banks. Since then, the sector has considerably
stabilised.
We all know that the functioning of the financial system matters to everyone - to the
economy at large and also to each one of us. The Nigerian economy has huge potential for
growth. To realise that potential, it is imperative that we learn lessons from the crisis and take
steps to not only fix the problems, but also introduce measures to establish financial stability,
enable a healthy evolution of the financial sector and ensure the banking system contributes
to the development of the real economy. The country, like many others hit by financial crises,
is already feeling the pain of financial meltdown, most evident in the slowdown of credit to the
economy. This is a natural consequence of bad lending decisions by banks leading to huge
provisions and erosion in their capital, as well as challenges resulting from lack of progress in
reforming the macroeconomic environment.
During this speech, I would like to talk to you about what went wrong within Nigeria's banking
industry and the measures the Central Bank of Nigeria is taking to reform the industry, to
ensure a similar crisis does not happen again and that the financial sector in Nigeria develop
in a sustainable manner, contributing positively to economic growth.
The original title of this paper was "Transformative Disruption: Relocating the Nigerian
Banking Crisis from the Economic to the Social". The choice of title was informed by a strong
desire to articulate a correct narrative, in an environment in which we are confronted by a
multi-vocal opportunism determined to subvert history through the fabrication of false
narratives. Among these, is the assertion that the actions taken by the Central bank are part
of a grandiose "northern" agenda against southern Nigeria. Or that perhaps it is an "Islamic"
agenda being pushed by a Muslim fundamentalist. There are also other subtler and more
sophisticated-albeit just as opportunistic-narratives. For example the new claim by public
officers and politicians that there is really no corruption in the public service, that politicians
are not corrupt, and that the real corruption is only in banks.
My initial plan was to address these narratives, for as a student of Social Theory I am fully
conscious of the reality that crises are often the spaces in which false consciousness finds its
articulation. Do we not remember Hitler, and how in post-war Germany he was able to
construct the narrative of Nazism and convince Germans that their problem was all caused
by the Jews and would end with the extermination of the Jews? Strange and ridiculous as
this seems to us today, it was a narrative fervently believed by many otherwise rational
people. It is therefore imperative for us to confront headlong these narratives and not just
dismiss them lightly, for in times of insecurity we always gravitate towards a Popperian
tribalisation, and confrontations intensify on a mythical plane of constructed-and
contestedidentities.
In a sense the initial title was inspired by recognition of a sad reality, which needs to be
mentioned at the outset. In a moment of such momentous change in our economy and society
the universities have been as silent as graveyards. Discourse on the banking crisis has been
left to journalists of varying degrees of sophistication, and to faceless agents and charlatans.
The voice of the intellectual has been noticeable in its absence. And this is a real tragedy.
It is tragic because the reforms represent transformational moment for our country if only
progressive intellectuals grasped it. What we have done in the Central bank, is to fire the
opening salvo in what could potentially be a revolutionary battle against the nexus of money
and influence that has held this country to ransom for decades. This would not be the first
time banks collapse nor are brought to the brink in our national history. And it will certainly
not be the last. But this time there is a difference.
In previous crises we said some banks had failed a passive and complicit phrase that masked
a gross irresponsibility and crass insensitivity. "The bank has failed". This is somewhat like
coming across the corpse of a man whose throat was slit, or whose body is covered with knife
wounds or riddled with bullets and saying "the man died". The man did not die. He was killed.
He was murdered. And he did not kill himself. To use the term "death" instead of "murder",
excuses us from the responsibility of finding the killers and bringing them to book.
And that is exactly what happens when we refer to "failed banks" as if the bank itself, some
impersonal structure made up of branches and computers, somehow collapsed on its own.
By using - or abusing - the term "failed bank" we are able to mask what is almost always a
monumental fraud. But it is a deliberate act of prestidigitation. Failed banks are handed over
to NDIC. Insured depositors get paid N50, 000 (later increased to N200, 000). Thousands of
poor people, who have kept their life savings in the bank, lose it. Children's school fees,
savings for retirement, medical bills, gone into thin air. And who is to blame? No one really.
Or maybe the poor people who were foolish enough to keep their money in a bank that
"failed".
How many people have died of heart attacks due to this tragedy? How many honest
businessmen have been rendered bankrupt? How many people have committed suicide?
How many have died because they were unable to pay medical bills as their monies were
trapped in these institutions? How many children have dropped out of school? We do not
know. Because we live in a society in which they do not matter. They are anonymous. They
are poor.
What we do know is that we have today, among those parading themselves as role models
in society, people who profited from failed banks. Owners and managers who go on to
become governors and senators. Bad debtors who are multi-billionaires, having taken the
money belonging to those poor dead souls and not paid back.
So here is the reality. The owners and managers of banks, the rich borrowers and their
clients in the political establishment are one and the same class of people protecting their
interest, and trampling underneath their feet the interest of the poor with impunity.
So this time we turned the tables and said "enough is enough". The banks did not fail. They
were destroyed and brought to their knees by acts committed by identifiable people. As a
student in Ahmadu Bello University, in the Faculty of Arts and Social Sciences (FASS), and
later as a lecturer in the same faculty, one of my chief mentors was my uncle, the late
Dr Yusufu Bala Usman. And one thing Bala taught us was we should never shy away from
naming names and calling a spade a spade. Do not say that government money has been
stolen. Name the thief. And so, in keeping with that tradition, we did not say that banks had
failed. We named human beings - the management that stole money in the name of
borrowing, the gamblers that took depositors funds to speculate on the stock market and
manipulate share prices, the billionaires and captains of industry whose wealth actually was
money belonging to the poor which they "borrowed" and refused to pay back.
Fortunately, the President, Umaru Musa Yaradua, understood from the first day that this was
an ideological choice we had to make. We could side with the rich and powerful, and say the
banks had failed. Or we could side with the poor and save the banks but go after the
criminals. And we chose the latter. And the battle was joined.
This was going to be the subject of my paper. A paper in social theory, locating the on-going
banking issues in the context of the social. I had wanted to challenge the audience on the
silence of progressives, and the failure to seize this opportunity to increase the pressure on a
corrupt establishment. We have come this far with the support of a president who has time
and again shown his willingness to back us in the struggle. The real challenge is to extend it
to other spheres of society even while we pursue the reforms to a logical conclusion. That
was the plan, before it changed.
The choice of a new topic, albeit a wider one, was informed by the emergence of a new,
more subtle and thus more dangerous narrative. The narrative, which is fast gathering
momentum, and being fuelled by articles, advertorials and opportunistic editorials, is that the
Central bank really has no strategy. There is no road map to the reforms. A senior
government official even suggested that perhaps we are acting "as the spirit directs". It is
often the case that statements are made very lightly and take on a life of their own. The US
government is still undertaking its study of what went wrong on Wall Street. This started after
the restoration of relative stability and will be completed in about 15 months from now. In our
case we commissioned a detailed study with the involvement of Bank and external resources
to diagnose the problems and come out with solutions. For the last six months we have been
studying internal memos, various reports and correspondences, and also interviewing
regulators, bankers, business persons, government officials and all stakeholders. I am using
this platform to unfold the full details of the banking reform programme and to outline exactly
what went wrong and what we are going to do about it. Economics is a lot more boring than
social theory but bear with me and I will try to make it as painless as possible.
So now we return to economics.
2. What went wrong
2.1 Introduction
The Nigerian banking sector witnessed dramatic growth post-consolidation. However, neither
the industry nor the regulators were sufficiently prepared to sustain and monitor the sector's
explosive growth. Prevailing sentiment and economic orthodoxy all encouraged this rapid
growth, creating a blind spot to the risks building up in the system.
Prior to the crisis, the sentiment in the industry was that the banking sector was sound and
growth should be encouraged. The IMF endorsed the strength of the banking system to
support this growth. However, this sentiment proved misplaced. I believe 8 main
interdependent factors led to the creation of an extremely fragile financial system that was
tipped into crisis by the global financial crisis and recession. These 8 factors were:
1 Macro-economic instability caused by large and sudden capital inflows
2 Major failures in corporate governance at banks
3 Lack of investor and consumer sophistication
4 Inadequate disclosure and transparency about financial position of banks
5 Critical gaps in regulatory framework and regulations
6 Uneven supervision and enforcement
7 Unstructured governance & management processes at the CBN/Weaknesses within
the CBN
8 Weaknesses in the business environment.
Each of these factors is serious on its own right. Acted together they brought the entire
Nigerian financial system to the brink of collapse. I will now discuss them in turn.
2.2 Economic and macro prudential management
Let me start with the macro-economic issues connected to the financial crisis. Although there
is some evidence of diversification, oil maintains an overly dominant position in the Nigerian
economy, introducing volatility and posing significant challenges to macro-economic stability.
As oil prices increased steadily between 2004 and 2008, Government spending tracked the
price of oil, making fiscal policy highly pro-cyclical and adding to this volatility. Variations in
monthly disbursement of oil revenues made it difficult for governments to manage economic
development and caused tremendous instability as these varying amounts entered the
banking sector.
Simultaneously, the lack of an effective fiscal quarantining mechanism meant that the fiscal
authorities failed to prevent this excess liquidity from reaching the domestic banking system.
Banking sector activity closely mirrored the price of oil and its volatility. As amounts held in
Nigerian deposits increased, banks were able to increase their lending. Consolidation in the
domestic banking sector and along with abundant capital increased the speed of credit
creation. Bank deposits and credit, tracking the price of oil, grew four-fold from 2004 to 2009
and banking assets grew on average at 76% per annum since consolidation.
There was a belief that financialisation would drive economic growth. However, the reality is
more complex. While many developing countries have followed this path, Nigeria's
financialisation was far too rapid for the real economy to benefit. The economy was not able
to absorb of the excess liquidity from oil revenues and foreign investments in productive
sectors. This resulted in significant flows to non-priority sectors and to the capital markets,
mostly in the form of margin loans and proprietary trading camouflaged as loans.. As a result,
market capitalisation of the NSE increased by 5.3 times between 2004 and its peak in 2007,
and the market capitalisation of bank stocks increased by 9 times during the same period.
This set the stage for a financial asset bubble particularly in bank stocks. The rapid rise in
asset prices and the over concentration of bank shares in the stock market index were clear
indications of an accident waiting to happen. Instead of raising concern among regulators,
these developments were cheered by most, and voices of protest were waved aside with
arrogance. In 2007, the Nigerian Stock Exchange was "the best performing" bourse in the
world even though there was no evidence to suggest a commensurate improvement in the
fundamentals of real sector corporations.
All other countries that experienced equally rapid financial asset growth crashed and suffered
years of low or negative growth. As credit levels rose and stock prices inflated, the CBN
failed to halt this vicious circle and foresee the consequences. The CBN did not highlight or
failed to communicate the problem to fiscal authorities and the market in general. The sad
story in all this is that we now have evidence that junior officers in the CBN did document
their concerns to CBN top management at that time, but no action was taken. We also have
evidence that the NDIC documented its concerns but its efforts to get the CBN leadership to
act quickly were rebuffed. Also, during this period, CBN's macro-prudential management did
not sufficiently address the impact of these oil-related inflows, and with the fiscal policy being
pro-cyclical, this exacerbated the crisis.
2.3 Corporate governance at banks
The huge surge in capital availability occurred during the time when corporate governance
standards at banks were extremely weak. In fact, failure in corporate governance at banks
was indeed a principal factor contributing to the financial crisis. Consolidation created bigger
banks but failed to overcome the fundamental weaknesses in corporate governance in many
of these banks. It was well known in the industry that since consolidation, some banks were
engaging in unethical and potentially fraudulent business practices and the scope and depth
of these activities were documented in recent CBN examinations.
Governance malpractice within banks, unchecked at consolidation, became a way of life in
large parts of the sector, enriching a few at the expense of many depositors and investors.
Corporate governance in many banks failed because boards ignored these practices for
reasons including being misled by executive management, participating themselves in
obtaining un-secured loans at the expense of depositors and not having the qualifications to
enforce good governance on bank management. In addition, the audit process at all banks
appeared not to have taken fully into account the rapid deterioration of the economy and
hence of the need for aggressive provisioning against risk assets.
As banks grew in size and complexity, bank boards often did not fulfil their function and were
lulled into a sense of well-being by the apparent year-over-year growth in assets and profits.
In hindsight, boards and executive management in some major banks were not equipped to
run their institutions. The bank chairman/CEO often had an overbearing influence on the
board, and some boards lacked independence; directors often failed to make meaningful
contributions to safeguard the growth and development of the bank and had weak ethical
standards; the board committees were also often ineffective or dormant.
We have already published details of the extent of insider abuse in several of the banks.
CEOs set up Special Purpose Vehicles to lend money to themselves for stock price
manipulation or the purchase of estates all over the world. One bank borrowed money and
purchased private jets which we later discovered were registered in the name of the CEO's
son. In another bank the management set up 100 fake companies for the purpose of
perpetrating fraud. A lot of the capital supposedly raised by these so called "mega banks"
was fake capital financed from depositors' funds. 30% of the share capital of Intercontinental
bank was purchased with customer deposits. Afribank used depositors' funds to purchase
80% of its IPO. It paid N25 per share when the shares were trading at N11 on the NSE and
these shares later collapsed to under N3. The CEO of Oceanic bank controlled over 35% of
the bank through SPVs borrowing customer deposits. The collapse of the capital market
wiped out these customer deposits amounting to hundreds of billions of naira. The Central
Bank had a process of capital verification at the beginning of consolidation to avoid bubble
capital. For some unexplained reason, this process was stopped. As a result, we have now
discovered that in many cases consolidation was a sham and the banks never raised the
capital they claimed they did.
2.4 Investor and consumer sophistication
Bank boards are hardly the only ones to blame for failure to deal with the sudden surplus in
capital. A lack of investor and consumer sophistication also contributed to the crisis by failing
to impose market discipline and allowing banks to take advantage of consumers. Investors,
many new to investing, were unaware of the risks they were taking and consumers were
often subjected to poor service and sometimes hidden fees.
Nigeria does not have a tradition of consumer activism or investor protection and as a
consequence many Nigerians made investments without a proper understanding the risks.
The limited consumer protection framework did exist in Nigeria. However, the framework was
inadequate and as a result consumers' rights were not sufficiently protected.
2.5 Disclosure and transparency
Given the low sophistication among many consumers and investor, inadequate disclosure by
the banks was another major contributing factor to the crisis. Bank reports to the CBN and
investors often were inaccurate, incomplete and late, depriving the CBN of the right
information to effectively supervise the industry and depriving investors of information
required to make informed investment decisions.
The CBN did not act to enforce the data quality in banks to ensure their reports were
accurate. The CBN's internal reporting system could not serve as an effective warning
system for bank surveillance.
In addition, banks made public information on their operations on a highly selective basis and
investors were unable to make informed decisions on the quality of bank earnings, the
strength of their balance sheets or the risks in their businesses. Without accurate
information, investors made ill-advised decisions regarding bank stocks, enticed by a
speculative market bubble which was allegedly partly fuelled by the banks through the
practice of margin lending.
Some banks even engaged in manipulating their books by colluding with other banks to
artificially enhance financial positions and therefore stock prices. Practices such as
converting non-performing loans into commercial papers and bank acceptances and setting
up off-balance sheet special purpose vehicles to hide losses were prevalent. Recently the
CBN put an end to these practices and the collapse of the equity markets effectively put an
end to alleged stock price manipulation.
2.6 Regulatory framework and prudential regulations
Now I will turn to the failure of the authorities, the CBN and other government bodies with
oversight for the financial sector. Lack of co-ordination among regulators prevented the CBN
from having a comprehensive consolidated bank view of its activities. In addition, regulations
concerning the major causes of the crisis were often incomplete.
There is little co-ordination among the FS regulators. In spite of the widespread knowledge of
bank malpractice and propensity for regulatory arbitrage, the FSRCC, the coordinating body
for financial regulators did not meet for two years during this time. Whilst excess capital gave
rise to strong growth in lending, banks were also allowed to use the capital to enter many
other non-lending activities such as stock market investments, most of which were hived off
in subsidiaries thus escaping the ongoing supervisory scrutiny by the CBN. The CBN did not
receive examination reports from the SEC covering bank subsidiaries, nor was there a
framework for consolidated bank examination.
Regulations governing the issues that caused the crisis were incomplete. In fact, of the
373 circulars issued by the CBN since January 2008, only 44 addressed issues relating to
the crisis and none addressed the issue of corporate governance. A comparison of Nigerian
regulations with those of international regulators indicated the Nigerian set of regulations was
not as comprehensive. An example was the lack of a legal and regulatory framework
governing the margin lending activity.
2.7 Supervision and enforcement
Uneven supervision and inadequate enforcement also played a significant role in
exacerbating the problems associated with the crisis. Regulators were ineffective in
foreseeing and supervising the massive changes in the industry or in eliminating the
pervasive corporate governance failures.
The Supervision Department within the CBN was not structured to supervise effectively and
to enforce regulation. No one was held accountable for addressing the key industry issues
such as risk management, corporate governance, fraud, money laundering, cross-regulatory
co-ordination, enforcement, legal prosecution or for ensuring examination policies and
procedures were well adapted to the prevailing environment. Moreover, the geographic
separation of on-site and off-site examiners hindered the building of integrated and effective
supervisory teams. Critical processes, like enforcement, pre-examination planning and
people development were not delivering the results required to effectively supervise and
engage banks to enforce good conduct.
There were many instances of weaknesses in the supervision and enforcement process. For
example, bank examinations were not conducted on a bank consolidated basis.
Preexamination planning did not question banks' use of the Expanded Discount Window nor did
it include a review of prior SEC or NAICOM reports (if any) on bank subsidiaries. In addition,
the CBN did not provide input to the SEC in planning its examinations of bank activities. Also,
the ratings and depth of analysis wasn't sufficient to capture the issues. For example,
CAMEL ratings did not differentiate the performance of successful and failed banks. While
some examinations identified critical risk management issues, many issues that caused the
crisis escaped examination, though they were well known in the industry. Sense of urgency
was low with some examinations taking between 9 months to more than a year to complete.
Enforcement was the biggest failure among surveillance processes, despite the CBN having
all the powers it needed to enforce examination recommendations. Financial penalties are
inadequate to enforce bank compliance. By paying fines, banks effectively annulled key
aspects of the examination reports. With examination cycles between 6 and 12 months,
follow-up on examination recommendations rolled into the following year's examination. The
prevailing view that the sector was healthy, a culture of tolerance, and acceptance of the
status quo and the shortage of specialist skills compromised supervision's effectiveness.
There was insufficient discipline in holding the banks to clear remedial programmes. While
banks responded to examination reports, they seldom committed to specific deliverables,
timing or executive responsibility for implementation. Hence it was difficult to measure bank
progress against compliance with some of the major recommendations. Banks' compliance
record was poor. They frequently ignored the examiners recommendations in spite of the
seriousness of the issues. The consequence to the banks of noncompliance was not
sufficient to change behaviour. Directors faced no personal consequences for
non-compliance. The CBN allowed this practice and behaviour to go unchecked, establishing
a way of doing business that compromised the supervision process.
2.8 CBN governance and management processes
Still on the role of the authority in this crisis, the governance and management processes at
the CBN also had a significant impact on its ability to deliver its mandate adequately.
Governance and internal processes were unstructured and this compromised the CBN's
ability to supervise the industry. Corporate governance at the CBN was laissez-faire. Board
agendas were set by the Governor and consequently reflected his priorities, and there were
inadequate committee structures and processes to ensure the CBN Board's independence in
assessing whether the CBN was fulfilling its mission.
Issues concerning the stability of the financial sector and economic development were not
discussed comprehensively at the CBN Board meetings - these risks include for example,
global economic risks, federal/state economic development strategies and fiscal policies,
formation of asset bubbles, exchange rate risk, capital market depth, informal sector
economy etc.
The CBN was not organised to monitor adequately and analyse the macroeconomic issues
and systems risks inherent in the financial sector. There is no overarching architecture to
manage the risks in the banking system, linking economic indicators to macro-prudential
guidelines and to individual bank prudential guidelines. As a consequence, managing the
risks to the banking system from the impact of oil price volatility, cross-border capital flows,
asset price bubbles and weak corporate governance did not have the necessary urgency at
the CBN board or within the CBN itself. Management information to analyse the risks in the
banking system was inefficient. There were also data quality issues with the CBN's internal
reporting system and the research department at the CBN is under-equipped to access the
latest economic data and analysis.
Leadership and culture issues included an apparent lack of political will to enforce the
sanctions for infractions and a belief, supported by the IMF that the sector was sound and
that growth was a healthy development blunted the understanding of the real risks
threatening the economy and the banking system. It was almost as if, having made
"consolidation" the hallmark of success, there was a desperate need to remain in a state of
denial rather than recognise that mistakes had been made and take corrective action.
2.9 Business environment
Finally, a lack of a sufficiently developed infrastructure and business environment has had a
negative influence on the banking industry. The legal process, an absence of reliable credit
rating agencies and poor infrastructure all contributed to non-standard banking practices.
Nigeria's legal process is long and expensive and banks seldom pursue borrowers in court.
Few banks were able to foreclose on borrowers, and this led to borrowers abusing the
system.
Basic lack of credit information on customers, largely because there is no uniform way to
identify customers, has held back the development of credit bureaus and hampered
customer credit assessment at banks, increasing the stock of bad debt in the system.
3. Reform program
3.1 Introduction
Having discussed the causes of the financial crisis let me turn on to the solutions that we are
pursuing. The blueprint for reforming the Nigerian financial system in the next decade is built
around 4 pillars.
- Pillar 1: Enhancing the quality of banks
- Pillar 2: Establishing financial stability
- Pillar 3: Enabling healthy financial sector evolution
- Pillar 4: Ensuring the financial sector contributes to the real economy.
In many areas, CBN needs to take the lead in implementing reforms; in other areas, CBN
needs to play a key advocacy role.
3.2 Enhancing the quality of banks
Let me begin with the first pillar - enhancing the quality of banks. The CBN will initiate a
5 part programme to enhance the operations and quality of banks in Nigeria. The programme
will consist of industry remedial programmes to fix the key causes of the crisis. It will also
include implementation of risk based supervision, reforms to regulations and regulatory
framework, enhanced provisions for consumer protection, and internal transformation of
the CBN.
In the first part, the industry remedial programmes will include a set of initiatives to fix the
key causes of the crisis, namely data quality, enforcement, governance, risk management
and financial crime. These initiatives will be structured in such a manner that the banks do
most of the work to embed new behaviours in the industry, with the CBN playing a
crossindustry programme management role. A key plank of this programme is that we must hold
individuals responsible for their actions, we must pursue all criminal cases to their logical
conclusion and we must ensure that nobody, no matter how highly placed, is permitted t