One item of interest found in the employees ethical code published by Wells Fargo, is that they have established what they call EthicsLine. This allows employees to contact an investigator (employed by Wells Fargo) to report any violations of the ethics code. The line is anonymous under most circumstances; only reports that involve criminal activity are require that the caller states any personal information. This allows employees an avenue to report any unethical behavior safely. This is extraordinarily efficient way to promote ethical behavior. However, Wells Fargo did not implement this item by choice; it is now required by corporations by comply with the Sarbanes-Oxley Act of 2006. Therefore, it is unclear if Wells Fargo would have this option if it was not required of them.

Ethical Violations

Wells Fargo has been accused of unethical behavior frequently throughout the last decade. Most recently, there have been numerous complaints about predatory lending practices. The web is flooded with allegations of examples of predatory lending and since Wells Fargo is the largest mortgage lender in the country is certainly not exempt from these allegations. Watchdog groups such as the Inner City Press (ICP) document many of the resulting laws suits. One law suit in Baltimore, and another in Memphis, alleges that Wells Fargo charged high interest rates to people of color; they call them "ghetto loans."

Another interesting development listed on the ICP website is Wells Fargo's refusal to provide the State of California any assistance with its current financial crisis. This is fairly ironic for two reasons. The first is that Wells Fargo received a federal bailout...

The other is that California has leverage over Wells Fargo because it is in California's jurisdiction. However, when Wells Fargo was confronted with the issue they threatened to fill a lawsuit.
Culture Speculations

Though Wells Fargo has a well developed ethics code and process of reporting unethical behavior it misses on many marks. One reason that the code apparently fails Wells Fargo is that it is not significantly enmeshed in the corporate culture. The ethics code and the hotline are both required by the Sarbanes-Oxley Act and enforced by the Securities and Exchange Commission (SEC). Therefore Wells Fargo must maintain these to stay in compliance. If the culture does not fully embrace the ethical codes, then they only act as a window dressing that is in place for compliance issues and do not have a substantial impact on the organization.

Conclusion

Wells Fargo has a tremendous impact on the financial success of the United States due to its status as one of the country's "big four" banking institutions. One would suspect that Wells Fargo would have a well developed and functional ethical code in place. However, upon inspection, this may not be the case. It appears that a bulk of the material and processes that Wells Fargo have instituted represent a level of ethics that barely surpasses compliance. Due to the recent financial meltdown, pressure will be externally applied to Wells Fargo to meet ethical guidelines. This will either be from consumer pressure or, more likely, through regulation. However, it the cultural at Wells Fargo does not adopt the ethical code, it will remain at the compliance level indefinitely.