therefore develop the capacity of its employees to make good choices, not just permissible choices. so, how do you practice moral reasoning? bill dudley has offered what i thought was a good starting point. get rid of the notion that a separate morality applies at work than at home. 10 bankers — and, for that matter, lawyers — cannot check their morals at the door when they step onto a trading floor or into a courtroom. here are some other ideas, courtesy of a 2016 report by the financial conduct authority entitled “ behaviour and compliance in organizations. ” 11 the report argues, among other things, that ethical considerations need to remain salient in order to promote good choices. salience can be achieved by prompting about moral codes — through language that emphasizes words like “ moral, ” “ ethical, ” and “ good. ” discussions by leaders and key culture carriers — that is, esteemed colleagues regardless of rank in a hierarchy — can also help if they address ethical dilemmas that arise in the course of business decisions. finally, salience occurs through proximity of decision - makers to those affected by decisions. 12 so, look for ways to make the human consequences of choices more apparent. in my view, a habit or culture of considering what is right, and not merely what is permissible, will help any organization attract, retain, and develop high - quality employees. it will promote individual wellbeing and will contribute, over time, to an industry that makes fewer errors of judgment. do not rest above all, remember that this is a marathon, not a sprint. so your organization now has three lines of defense — great! but your work is not over. you still have to question whether your organization can be better controlled vis - a - vis its risks. the challenges and opportunities facing your firm do not stop changing. you need to adjust accordingly. i encourage you to ask questions about the three lines of defense model and how it is applied in your organizations. here is one of the questions on my mind : how do the three lines of defense take account of advances in technology? technological solutions in financial services are becoming cheaper, faster, more easily available — almost off - the - shelf — and help make your business more efficient and profitable. but do you know how these solutions work? chances are, not really. i certainly do not, but then i ’ m just a lawyer. there may be a tendency to believe 4 / 7 bis central bankers'speeches that brilliant people built and tested

to make and stick with good decisions. gatherings in which members of a profession can come together and exchange ideas and opinions are crucial. they help members of a professional community keep up to date on important industry - wide developments and raise issues that present the need for collaboration. they also help to instill a shared sense of purpose and responsibility for carrying out the goals of the profession. a profession can also provide personal accountability. lawyers, for instance, can be disbarred, and complaints against them can become matters of public record. that is added incentive to maintain the skills, character, and other qualifications required to become ( and remain ) a member of the bar. and, critically, professions do not stop improving. lawyers continue — i hope — to seek a more just society. doctors, a healthier one. i do not mean to call for the equivalent of the legal bar for bankers — although it might not be a bad idea. but there are elements of professions that could be useful. for example, forums like this one facilitate information sharing and promote a sense of community. a code of professional conduct is another example. again, i refer you to the work of the banking standards board, 5 / 7 bis central bankers'speeches which has developed a “ statement of principles for strengthening professionalism. ” like bill dudley, i have argued that banking would benefit from a misconduct database. 15 records of employee misconduct would be available to future employers to combat the so - called “ rolling bad apple ” phenomenon. hopefully this would encourage more careful choices by bankers in the same way that the risk of disbarment prompts lawyers to think about the long - term consequences of their decisions. none of these ideas is a magic bullet. but they may be helpful as you consider how the first line of defense and the financial services industry develop as a profession. conclusion : professional courage let me end with one final thought on professionalism. looking back at the financial crisis and more recent scandals, there must have been people who recognized early that what was happening was wrong, but remained silent. 16 as the first line of defense develops and convenes in gatherings like this, it is important to remember one other professional value : courage. professional courage is key to the appropriate functioning of lawyers inside corporations. 17 in what has been called the “ partner / guardian ” dilemma — a bit of a misnomer since the “ dilemma ” is really a good thing — lawyers are supposed to assist the firm in its mission and