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TUAN BUI 129107147]
Student Number TUAN BUI
Programme BA business management
Module Tutor
Module Code: 3BM150 Module Title: Business Ethics
Assignment Number:
Assignment Title:
Word Count:First Attempt/Re-sit/Deferred/Extension granted
First Marker’s feedback
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Date: Indicative Mark:
Second Marker’s or Moderator’s comments:
Second Marker:
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Moderator:Date: Indicative mark:
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TUAN BUI 129107147]
“I [Tuan Bui] declare that I am the sole author of this assignment and the work is a result of my own investigations, except where otherwise stated. All references have been duly cited”
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TUAN BUI 129107147]
Contents
I. The importance of business ethics and their impacts on the organization.............................3
II. Environmental analysis for HSBC to explore its practice in business ethics and analyses
the impacts on its stakeholders:.........................................................................................................5
III.Challenges posed by business ethics to both the selected organisation and its stakeholders.......9
IV. Recommendations to HSBC management as to how they should improve the
organizations’ current business approach:......................................................................................11
BIBIOGRAPHY:.............................................................................................................................12
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TUAN BUI 129107147]
I. The importance of business ethics and their impacts on the
organization
This part of the report will discuss about the importance of business ethics and illustrate the
effect of business ethics on businesses. To gain comprehension about these two mentioned
aspects, the first thing that should be mentioned is the definition of ‘business ethics’. In the
definition of Andrew Crane and Dirk Matten (2010), business ethics is ‘the study of business
situations, activities and decisions’ in which there are concerns about the ‘right’ and ‘wrong’
issues. In detail, the authors explained the issues of right or wrong are morally right and wrong
and they stated that the field of business ethics comprises of not only commercial businesses
(Andrew Crane and Dick Matten, 2010, pp5). Therefore the issues of business ethics also include
of other organizations such as non-profit organizations (NGOs), government organizations,
charities, et cetera. It is also claimed in the book that there are differences between the terms
‘ethics’ and ‘morality’. Authors agreed that ‘morality’ is concerned with issues that are relevant
with culture of an individual or a community such as ‘norms, values and beliefs’. On the other
hand, ethics, according to authors, are the study of how morality is applied in a given situation
where the issue of right or wrong is determined by the ethical theories- which are specific rules
and principles (Crane and Matten, 2010, pp8). According to Visser et al (2007 cited in Michael
Blowfield and Alan Murray, 2011, pp15), business ethics ‘is a sub-set of corporate responsibility
offering a crucial analytical tool for understanding, conceptualizing and legitimizing whether the
actions and behavior of companies is morally right or wrong’. This definition seems to have
familiarity with the given definition of Crane and Matten (2010). Blowfield and Murray also
stated that business ethics concerned with both of individual level and institution level. This idea
is supported by Johnson and his colleagues when they determined that business ethics exits at
two levels of macro level and individual level-actions and behaviors (Johnson, Scholes and
Whittington, 2008, pp145).
The next thing to be discussed is the importance of business ethics. Crane and Matten (2010)
has stated out seven reasons of why business ethics is important. Among those reasons, it can be
said that the most noticeable reason is the increase of business influence on the society. The
authors gave the evidences by citing the finding that 75% residents of more than 20 leading
economic nations believe that large corporations had ‘too much influence’ on governments’
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TUAN BUI 129107147]
decisions (Czywinski, 2008 cited in Crane and Matten, 2010). Businesses also provide several
contributions to the society such as providing jobs, products and services, paying taxes and so
on. Whether those contributions are positive or negative to the contemporary society is a
question that concerning with the role of business with the rise of ethical issues. Therefore,
authors believed that business ethics will give more comprehension about that issue and suggest
‘how we might address this situation’ (Crane and Matten, 2010, pp9). Since businesses now are
in the situations of internationalization and globalization, ethical violations could happen across
countries and sectors (Crane and Matten, 2010). That is the reason why with the comprehension
of business ethics, different stakeholders of the organization including managers or different
parties and individuals could make easier decisions of how to deal with those violations
problems. The authors also suggested that business ethics ‘can provide us with the ability to
access the benefits and problems associated with different ways of managing ethics in
organizations’. There are also rising in demand of different stakeholders in terms of
understanding and practicing business ethics. Collins (2009, pp10) showed the findings of a
survey in 2007 within American which stated that 94% of Americans believe that ‘it is “critical”
or “important” to work for an ethical companies’.
In terms of the influences that business ethics has on the organization, several authors had
done research in order to answer the question whether business ethics pays. Webley and Moore
(2003 cited in Fisher and Lovell, 2005) had shown their findings for the questions about the
impact of business ethics on organizations. Their research’s objects are the organizations with
and without the code of conduct. In terms of company’s rating, they found out that the
companies with code of conduct had better ratings for the one who did not in terms of SERM
(Social-Ethical Risk Management) rating and ‘Britain’s Most Admired Companies’ (Webley and
More, 2003 cited in Fisher and Lovell, 2005, pp11). Denis Collins (2009) stated that there are
several competitive advantages for ethical organizations. The competitive advantages that he
found out comprises of better relationship within different stakeholders that will help companies
attract and retain them. According to the author, companies who are ‘ethical and trustworthy’
also earn goodwill with other stakeholders like community and government as well.
Additionally, one of the most worth-mentioning competitive advantages is that with the uses of
business ethics, companies can achieve greater efficiency in decision making based on ‘more
reliable information from stakeholders’ (Collins, 2009, pp8).
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TUAN BUI 129107147]
II. Environmental analysis for HSBC to explore its practice in business
ethics and analyses the impacts on its stakeholders:
HSBC Plc. will be the organization that is chosen in order to carry out the environmental
analysis- mainly stakeholder analysis to explore whether it recognises, values and manages
business ethics effectively and analyse the impact on its stakeholders. In order to find out
whether HSBC recognizes, values and manages business ethics effectively, this report will
examine the practice of HSBC in reality as well as in the code of conduct that they has
established. For further comprehension of how effective HSBC is in terms of business ethics
practices, it is crucial to scrutinize its practices toward specific stakeholders. This report will
focus on some key stakeholders of HSBC such as the managers, customers, shareholders,
employees, government and civil society. In the case of HSBC, the organization also set up its
own values that connected with customers, communities, regulators and each other. These values
including of two statements in which HSBC commits to:’ Building connection, being aware of
external issues, collaborating across boundaries’ and ‘Caring about individuals and their
progress, showing respect, being supportive and responsive’ (HSBC,2013). The company is also
aware of the community in which it is operating with the set-up of sustainability strategies. It is
stated in HSBC website that the success of HSBC including of providing customers with needed
products and services, understanding and managing its impact on society and environment as
well as investing in the future of its employees and the communities in general (HSBC, 2013).
The group chairman of HSBC- Douglas Flint stated: we have responsibilities not only toward
our customers, employees and shareholders but also to the countries and communities in which
we operate’ (HSBC, 2012). This report will examine the practice of how effectiveness those
sustainability strategies are in practical with the information given by HSBC as well as from
other sources.
The first stakeholder that the report will discuss is shareholder of HSBC. In terms of
shareholders, it is one of the main stakeholders of HSBC Plc. with the total population of
220,000 shareholders from London, Hong Kong, New York, Paris and Bermuda Stock Exchange
(HSBC, 2012). For its shareholders, HSBC set the shareholder communication policy as a
guideline for any practice with shareholders based on HSBC’s values. Within this policy, HSBC
stated out different issues in communicating with its shareholders in which there are guidelines
of how HSBC should communicate with the shareholders via different communicating channels
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such as websites, annual reports including of financial and sustainability reports, annual general
meetings (AGM) and so on. It is said in the policy that ‘shareholders are encouraged to attend the
AGM in the United Kingdom or the Informal Meeting of Shareholders (IMS) held in Hong
Kong’ (HSBC, May 2012). In practice, HSBC ran a program of ‘906 senior executive meetings
with representatives of institutional shareholders in 27 countries and territories’, according to
HSBC Sustainability Report 2011 (HSBC, 2012). It is also can be seen how HSBC issues the
importance of its shareholders with the plan to bump up its first three interim dividends for next
year by 11 per cent to 10 cents a share (Harry Wilson, 2013). The next stakeholder to be
discussed is the managers of HSBC Plc. Managers are the key employees of HSBC including of
the Board of Directors and the Senior Managers. For this stakeholder, HSBC Plc. sets out the
governance practices where the obligations for Senior Financial Officers (including of the Group
Chairman, Group Chief Executive, Group Finance Director and Group Chief Accounting
Officer) require the financial officers to ‘engage in honest and ethical conduct’ and to ‘ take such
measures as appropriate to assure that HSBC complies with all applicable governmental laws,
rules and regulations…’ (HSBC, 2013). The governance practices also give recommendations
for its senior financial officer to avoid conflicts of interest and should report promptly to the
Chairman of Group Audit Committee any violations that she or he is aware (HSBC, 2013).
Employee is one of the key stakeholders that are worth mentioned also. According to
Marketline (2012), the total numbers of HSBC’s employees are 298,000. HSBC designed the
HSBC Employee Handbook which provides terms and conditions of employment, guidance on
the standards of conduct that are expected of the employees as well as the main benefits that
employees can get for working in HSBC. In this handbook, there is a specific section which is
called the code of business ethics and responsible behaviour (section 2-the code). The section
includes of several principles that HSBC expects form any employee which consists of three
main principles- integrity, fidelity and self-respect (HSBC, 2008). Moreover, this section also
includes of corporate values that the company subscribes and also the core standards of
behaviour for its employees. It can be seen that those principles are stated clearly for the purpose
of inform promptly and fully for the employees about the comprehension of the codes of ethics.
In practice, HSBC also values its employees via the employee engagement. It is reported that 81
per cent of its workforce participated in the annual Global People Survey which is designed to
give employees ‘the opportunity to feed back their priorities and concerns’ and ‘ in identify
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TUAN BUI 129107147]
actions to improve their engagement’. The example actions, according to HSBC Sustainability
Report 2011, includes of job sharing, encouraging better work-life balance or part-time working
programmes, et cetera (HSBC, 2012). The report also stated that there are a rise in the percentage
point of employee engagement which made up to 69 per cent in 2011, which leads to ‘seven
percentage higher that the external global average’. There might be some issues that the
employees should concern in this year since HSBC announced to eliminate 30,000 jobs by 2013
to ‘improve efficiency’ as a part of global cost-cutting plan for sustainable successes (HSBC,
2012). Sparkes (2012) indicated the UK reduction numbers will be 2,217 employees after having
950 new positions. In its report, HSBC stated that the company regrets with the employee loses
however also said that it is curial to ‘remain competitive’ for long-term successes. It also
committed to investigate in faster growing segment in order to create new and sustainable jobs
(HSBC, 2012).
In terms of customers, HSBC serves about 89 million customers in 85 countries and
territories (Marketline, 2013). According to HSBC, the company engages with its customers
through wide variety of channels including both written and electronic communications as well
as client events, customer panels and one-to-one meetings (HSBC, 2012). As a multinational
organization, HSBC understands that it is important to meet the expectation of customers for
long-term business. In addition, as a business, HSBC also has the responsibilities to access the
environmental and social impacts that is lending and investment can have. HSBC is a large
corporation with 4 main business activities including: Commercial Banking, Global Banking
and Markets, Private Banking, Retail Banking and Wealth Management. Each of its business
also has its own management for the long-term sustainability. For instance, about the Retail
Banking and Wealth Management (RBWM), its main object is to meet the daily customers’
needs in the major markets of UK, Hong Kong, France, the US, Mexico, Brazil and Turkey. The
main activities of RBWM includes of helping people meet their long-terms ambitions. For
example, in 2011, new mortgage lending in Brazil grew by 85 per cent. RBWM also widen
access for helping customers. In UK, RBWM established the UK Management Team to support
customers before they go into arrears, helping customers to avoid the stress of missed payments,
for instance. It is said that the team has helped over 70,000 people since it was set up (HSBC,
2012). About the global private banking, the main activities in terms of sustainability of HSBC is
to sustain wealth for future generations, social finance, Islamic finance, responsible investment
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TUAN BUI 129107147]
and preventing crime (HSBC, 2012). About the community as a stakeholder, the total community
investment in 2011 of HSBC was US$m 115.7 ranges from education programs, environmental
programs and engagement to customers, people and communities (HSBC, 2012).
It can be said that with the comprehension of sustainability and ethics practices, HSBC had
set up several principles and ethics code with the involvement of as much as stakeholders as they
can for the purpose of become trustworthy and sustainability. However, in practice, HSBC also
has several scandals that related to the violations of business ethics. They had several scandals
that involve with customers. For instance, HSBC lost thousands of customers’ details in 2009
and was fined 3 million pounds for that (Moore, 2009). Moreover, the Financial Services
Authority (FSA) found HSBC was guilty of mis-sold complicated financial contracts to hundreds
of small-to-medium enterprises (Brinded, 2012). One of the biggest scandals of HSBC is the
scandal in the United State that involved with criminals. According to BBC (2012), US Senate’s
report showed that HSBC was failed to stop criminals using the bank for money-laundering. The
main findings of this 300-page report showed that HSBC Mexico had ‘high-profile clients in
drug trafficking’ and the HSBC US failed to properly monitor transfers between the two banks.
Moreover, it is said in the report that HSBC US carried out transactions with Iran- a country that
was prevented to do business by the US laws, during the period from 2001 to 2007. The banks
also found guilty including with violations in the Middle East whilst its branch was doing
business with Al Rajhi Bank- which had the owners had links to ‘financial organization
associated with terrorism’. That last finding is that HSBC cleared large amounts of travelers’
checks without proper anti-money laundering controls, despite evidence of suspicious activity
(BBC, 2012). Due to those scandals, HSBC had to pay 1.9bn US dollars for penalties (BBC,
December 2012). The firm responded with the sorry of chief executive Stuart Gulliver and
admitted that the complex structure makes it difficult to control the money-laundering structure
(Roland, 2013). For fixing the scandal, the bank also appointed a new director of financial crime
compliance- a newly position (Werdigier, 2012). The scandals also have effects on various
stakeholders. For instance, due to the penalties payment, HSBC had to decrease the bonuses of
employees. In detail, bonuses across the bank decreased $4.2bn to $3.7bn (Wilson, 2013). The
CEO was also been forced to forfeit £1.3 million of his bonus (Salmon, 2012). HSBC was also
criticized by activists of still having hug bonuses after those scandals. More (2013) quoted the
saying of activists that: “it is beyond belief that in a year marked by dodgy dealings, 200 of
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TUAN BUI 129107147]
HSBC’s top brass are celebrating bonuses greater than many people earn in lifetime”. With such
of those critics and scandals, it can be said that HSBC still had problems in terms of business
ethics management even when they had aware of the importance of business ethics. It can
concluded that HSBC still has challenges in terms of how to manage business ethics effectively
both in the view of the company and from the view of its stakeholders. The next part of this
report will discuss about those implied challenges that the firm can have.
III. Challenges posed by business ethics to both the selected organisation
and its stakeholders.
In the circumstance of HSBC Plc., the brand has recognised the importance of business ethics
has set out several principles and conduct codes for its different stakeholders. The evidences for
that can be found in its values as well as their sustainability report. However there are still
problems that it faces in reality. The report will point out some of the possible challenges that
come from others researches. The first issue that can be pointed out is the uses of shareholder
theory or stakeholder theory of the company, or in a broader context- the corporate governance.
Definition of corporate governance is that corporate governance is ‘concerned with the structures
and systems of control by which managers are held accountable to those who have a legitimate
stake in an organization’ (Jacoby, 2005, cited in Johnson, Scholes and Whittington, 2008). By
the means of the one who was held accountable of the managers, the authors said that it is argued
that corporations need to be more accountable to wider social interest, not only to the owners and
managers of the corporation only (Johnson, Scholes and Whittington, 2008, pp133). According
to Sun (2002 cited in Nwanji and Howell, n.d), the issue of corporate governance has centered
on’ whether shareholder-ship or stakeholder-ship was best for corporations and society’ and
which one should the corporation follow to. There are different frameworks in term of corporate
governance globally. In the case of HSBC, it can be believed that the firm is using the Anglo-
American model. The Anglo-American model, according to Crane and Matten (2010, pp241), is
the model which focuses on the stock market as a ‘central element of the system of governance’.
Also according to the authors, the goals of ownership in the Anglo-American model are the
shareholder value and short-term profits, which also results to shareholders is the key
stakeholders in the model (Crane and Matten, 2010, pp242). However, the shareholder-ship
governance model has the problem where several authors stated:’ this created the agency
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TUAN BUI 129107147]
problem where managers push short-term policies that lead to their own interests against the
long-term profits objectives of the shareholders (Manne, 1965; Friedman, 1970; Jenson and
Meckling, 1976 cited in Nwanji and Howell, n.d). The agency relation between shareholder
(principal) and manager (agent) can create dilemmas which are the conflict of interests or
informational asymmetry (Shankman, 1999 cited in Crane and Matten, 2010, pp240). Conflict of
interests of the agent is to seek remuneration, power, esteem, et cetera. In order to achieve their
interests, manager can go against the will of shareholder- seeking profit or rising in share price.
The principle has only limited knowledge and insight into the actions and goals of the agents-
which is called informational asymmetry. The example given by authors is about the Porsche
shareholder when they are happy with the profitability of the company however ‘had limited
insight into the actual running and the risks associated with it’ (Johnson and Scholes 2002: 332-
40 cited in Crane and Matten 2010: pp240).
In terms of the stakeholder-ship approach, it is also have criticism from different authors
cited in Nwanji and Howell. Stenberg (2004 cited in Nwanji and Howell, n.d, pp7) claimed that
since each stakeholder has own interest, the manager can become unaccountably for their
actions. Authors also suggested that the reason why firms to follow stakeholder theory might be
that the stakeholders’ interest meet with director’s own interest, therefore can lead to
‘opportunistic directors could more easily act in their interests’ (Phillip, 2003; Marcoux, 2000;
Stenberg, 2004 cited in Nwanji and Howell, n.d). The journal gave the example in 2003 while
total revenues of world’s largest corporations- about 500 groups of CEOs, are 14.9 trillion US
dollars while millions of workers after contributing to such achievements ‘lost their jobs and
continue to suffer in the name of maximising shareholders value’. It is also suited with the
criticism of the activists for HSBC that given above of Moore (2013). There is another
suggestion of why sustainability cannot make into reality, which is the suggestion where
stakeholders perceptions are differ from corporate reality (Peloza, Loock, Cerruti and Muyot,
2012). The authors, in their article, try to find out the answers by examine stakeholders’
perception of the sustainability activities of firms, and compare that perception with the reality of
a firm’s investment in sustainability. The findings of ‘why does perception not meet reality’ can
be due to the communication problems within the company. It is said that due to the message
delivery was caused problem by noise can distract the audience from the original message, which
can cause to the different in perception and reality.
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TUAN BUI 129107147]
IV. Recommendations to HSBC management as to how they should
improve the organizations’ current business approach:
As a large multinational organization, it is hard to change its approach in their corporate
governance. However to improve the current business approach of the firms, it is still some
appropriate recommendations will be given in this report. Since it is stated that ‘a firm cannot
maximise value if ignores the interest of its stakeholders’ (Jansen, 2001 cited in Nwanji and
Howell, n.d.), it is crucial for HSBC to carefully plan their actions regarding the effects and
consequences that might occur for the environment and society as well, not only for the
economy. The recommendation is that HSBC should have the approach in business ethics
include of both deontological approach and teleological approach. The former is the approach
that states the duty for business ethics is basic moral category, ‘independent from the
consequences’ of the actions (Nwanji and Howell, n.d.). The latter is the approach where the
firm will examine the consequences to find out the actions are moral or not (Beu et al 2003 cited
in Nwanji and Howell, n.d.). HSBC should take into account that how such shareholder ‘value’
can affect the local and global communities hence have more internal controls and actions in
order to follow ethical codes that they set. According to Peloza, Loock, Cerruti and Muyot
(2012), to deal with the problems that stakeholders’ perception can differ from the sustainability
performance of the firm, they have several suggestions in terms of having more effective
delivery of sustainability messages. With different issues that can occur to distract the
sustainability messages, the journal stated out each recommendation related with each issues. For
instance, dealing with the negative category bias, the recommendation is ‘to align benefits of
sustainability with individual stakeholder group’s interest’. Another example is the issues related
with the conflict between sustainability and brand positioning, the suggestion is that to ‘integrate
sustainability message into positioning’ (Peloza, Loock, Cerruti and Muyot, 2012, pp89-90). The
authors of the article also gave suggestions for the firm in macro level such as HSBC. There are
two of those recommendations that could be used for HSBC. The first is responsibility is taken
for the impact of internal operations, as well as those of associated entities such as supply chain
partners’. That is the reason why HSBC should have more control in terms of their supply chains
after the scandals involving with dealing business with criminal-related bank. A suggestion for
that is to form alliances between banks or other sectors to foster the progress on targeted
sustainability issues. The second suggestion that worth to be mentioned is that firm should
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TUAN BUI 129107147]
‘understand that sustainability is more than reporting’. For large corporations, it is important to
integrate sustainability themes into their brand and customers value propositions for better
success.
BIBIOGRAPHY:
BBC News (2012) HSBC money laundering report: Key findings [Internet], December 2012.
Available from: http://www.bbc.co.uk/news/business-18880269 [Accessed 15 May 2013].
BBC News (2012) HSBC to pay $1.9bn in US money laundering penalties [Internet], December
2012. Available from: http://www.bbc.co.uk/news/business-20673466 [Accessed 14 May 2013].
Brinded, L. (2012) Libor fixing scandal: HSBC fix six rate probes as CEO admits bank’s failure.
IBTimes [Internet], July 2012. Available from:
http://www.ibtimes.co.uk/articles/368151/20120730/hsbc-libor-fixing-scandal-euribor-money-
laundering.htm [Accessed 14 May 2013].
Collins, D. (2009). Essentials of business ethics: creating an organization of high integrity and
superior performance. John Wiley & Sons Inc, pp8-10.
Crane, A. and Matten, D., 2010. Business Ethics. 3rd ed. Oxford: Oxford University Press.
Fisher, C. and Lovell, A., 2005. Business Ethics and Values. Harlow: Pearson Education,
pp11.
HSBC (2013) Obligations of senior financial officers [Internet] Available from:
http://www.hsbc.com/investor-relations/governance/obligations-of-senior-financial-officers
[Accessed 15 May 2013].
HSBC (2013) Our values [Internet] Available from: http://www.hsbc.com/citizenship/our-values
[Accessed 14 May 2013].
HSBC (2013) Sustainability [Internet] Available from:
http://www.hsbc.com/citizenship/sustainability [Accessed 14 May 2013].
HSBC, 2012. Sustainability report 2011, London: Corporate Sustainability, HSBC.
Johnson, G., Sholes, K., Whittington, R. (2008). Exploring corporate strategy. 8th ed. Harlow:
Prentice Hall.
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TUAN BUI 129107147]
Moore, J. (2009) HSBC hit with big fine after losing thousands of customers’ details. The
Independent [Internet], July 2009. Available from:
http://www.independent.co.uk/news/business/news/hsbc-hit-with-big-fine-after-losing-
thousands-of-customers-details-1757497.html [Accessed 15 May 2013].
Moore, J. (2013) Outrage as HSBC hand £2m bonus to Chief Stuart Gulliver after fine in US.
The Independent [Internet], March 2013. Available from:
http://www.independent.co.uk/news/business/news/outrage-as-hsbc-hands-2m-bonus-to-chief-
stuart-gulliver-after-fine-in-us-8518814.html?origin=internalSearch [Accessed 15 May 2013].
Nwanji, T., Howell, K (n.d.) The Stakeholder Theory in the Modern Global Business
Environment. International Journal of Applied Institutional Governance, 1 (1).
Peloza, J., Moritz, L., Cerruti, J., Muyot, M. (2012) Sustainability: How stakeholder perception
differ from corporate reality. California Management Review, 55 (1).
Roland, D. (2013) HSBC Chief admits complexity exposed the bank to crime. The Telegraph
[Internet], Feb 2013. Available from:
http://www.telegraph.co.uk/finance/newsbysector/banksandfinance/9852625/HSBC-chief-
admits-complexity-exposed-the-bank-to-crime.html [Accessed 15 May 2013].
Sparkes, M. (2012) HSBC to cut 3,167 jobs across the UK. The Telegraph [Internet], April
2012. Available from
http://www.telegraph.co.uk/finance/newsbysector/banksandfinance/9228306/HSBC-to-cut-3167-
jobs-across-the-UK.html [Accessed 15 May 2013].
Werdigier, J. (2012) HSBC names head of financial crime compliance. The New York Times
[Internet], December 2012. Available from: http://dealbook.nytimes.com/2012/12/10/hsbc-
names-head-of-financial-crime-compliance/ [Accessed 15 May 2013].
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