“However, I recognise that being sorry is not enough. We, as public servants, should not merely meet but exceed the standards we expect of others. Failure to do so risks undermining the public’s trust in us, something we cannot let happen. Furthermore, my integrity has, I believe, never been questioned throughout my career. I cannot allow that to change now. I am therefore resigning from my position. I will, of course, work with you through any transition.”
—-The Bank of England’s chief operating officer and incoming Deputy Governor for Markets and Banking, Charlotte Hogg, in her letter of resignation over criticism regarding a possible conflict of interest and her failure to report it.
Charlotte Hogg, a senior Bank of England official who had been named a deputy governor, resigned this week after a Parliament committee found that she had failed to disclose a potential conflict of interest: her brother held a senior position at Barclay’s during her time at the central bank. Hogg insisted that she never breached her duties or passed along any confidential information to her brother, but she had helped draft an industry ethics code of conduct policy required a disclosure of such conflicts. This creates doubts about her integrity, judgment competence, as well as the appearance of impropriety.
The Parliamentary committee recently issued a report finding that Ms. Hogg’s professional competence “short of the very high standards” required to be deputy governor, adding that her failure to disclose her brother’s role was a “serious error of judgment.”
This is one of my favorite kinds of conflicts, because it may be only appearances at stake. What if, as is often the case (sadly), Hogg and her brother are estranged? What if she doesn’t speak to him? What if they hate each other? Never mind: the public, not knowing this, will suspect that she might use her position to favor him or his bank, so disclosure is crucial to maintaining public trust. Not disclosing, in contrast, raises suspicions. Why didn’t she let everyone know about her brother? What was she hiding?
What if, however, her college room mate was the one working at the bank in a high position? How about her ex-lover, with whom she is still infatuated? What if her best friend in the world works there? Or someone who saved her life, or the life of her child? Any of these people might create a far greater potential conflict than a relative, but ethics rules typically only specify spouses and blood relatives. Ultimately, it is the individual, not ethics codes, that have to puzzle out what is ethical.
Hogg was found to be in violation of a compliance requirement, without any evidence that there was a real potential conflict at all. The appearance of one was enough. And the real conflict created by the presence in a senior position at Barclay’s of (let’s say) the woman she knew was the donor of the bone marrow that saved Hogg’s daughter from leukemia? No one will ever know, so there is no appearance of impropriety—only a genuine, lurking, serious potential conflict, caused by divided loyalties and emotional ties.
Hogg’s standard, however, is the correct one. Public servants should not merely meet but exceed the standards we expect of those who are not public servants. When they don’t meet those standards, public servants should resign on their own accord.