Eureka Case 25 min Ethics & Governance

Eighteen Branches

You are Zarina Yusof, Chief Governance Officer of Bank Pertiwi Berhad in Kuala Lumpur. On Monday 16 March 2026 an internal audit memo lands on your desk describing a pattern at eighteen branches. The board meets in fourteen days, the regulator has not been told and, before anything else, you must sign a written diagnosis of what happened.

The situation

Pertiwi is a mid-sized commercial bank: RM 92 billion in assets (Malaysian ringgit), 210 branches, 3.4 million customers and 8,600 staff. Since January 2023 it has grown its retail business on steep individual sales incentives and a monthly league table naming the top and bottom ten per cent of sellers across the network. Fee income rose, and the 2026 plan counts on 28% growth. You signed the governance clearance on the scheme in 2023; that review asked whether the targets were achievable and the payouts affordable.

The memo covers nine months at 18 branches, all in the top band of the league table: dormant accounts reactivated in clusters, about 2,400 customers who appear to have been sold credit-protection insurance they never asked for, and same-day cancellations that have tripled. Refunding and remediating those customers would cost RM 14 to 22 million. The quarterly staff survey adds that 41% of sellers feel pressure to sell unsuitable products (19% before the scheme), that 8% would report a colleague, and that the whistleblowing line has taken three reports in two years.

Lim Chee Kong, Head of Retail Banking and the scheme's designer, is clear: it is "a few bad apples in a network of 8,600 people", the league table is "healthy competition", and killing it would cost eight to ten points of fee growth next year. Bank Negara Malaysia, the supervisor, expects banks to report conduct problems promptly; where it finds a pattern itself, comparable cases have ended in a fine near RM 30 million and a mandated independent review. The March league table closes this week.

Your job in this case: weigh the evidence in the memo and the survey, work out what each reading would mean for the other 192 branches, and decide which diagnosis you sign. Everything you do in the fortnight will be built on it.

The decision

Which diagnosis do you sign?

  • A · A few sellers broke the rules
  • B · The sales checks failed
  • C · The reward design produced it

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