So, while doing my master’s I had decided to conduct some interviews on the nature and importance of interdisciplinary work. I wanted to see how collaboration and interdisciplinarity work in other fields and how it is in implemented.
The first of the interviews is of Sandra Lermer. She works at ING, and after the very first conversation I had with her, I felt that she would be a great person to interview. It just so happens that she was also a good friend of mine. We spoke about a lot of things, but mostly about her work and how interdisciplinarity fits into it.
So you work for ING is that right? Can you tell me what it is that you do?
Yes. My current job title is Compliance Officer, and I’ve been at ING for a year and one or two months.
So, ING has implemented a three lines of defence model, where the first line is the business; the second is, among other things, compliance or legal, and so on. Our role is to challenge, monitor and advise. Within the organization, we have the third line, and that is the corporate audit. That is how it is built up. What we are doing is, usually, for example, at the moment, our first line is drafting some documents and we are challenging and reviewing those documents, providing comments with respect to the law, but also from a holistic perspective with respect to process design, customer journey, and so on.
And for example, today, I was in a meeting with them discussing comments on how to move further with some documents. Then we have, of course, the advisory part where we are advising our first line, but also our local second line on how to interpret the policy. That is our Business as Usual (BAU).
Is there a lot of interdisciplinarity or multidisciplinarity in your work? In the sense that does the various departments talk to each other and work together, or are they independent departments?
So, I think within ING (personally, I perceive it as a very positive thing ) there’s a giant change in the mindset of the compliance that is going on at the moment, it’s not finished yet, but I think we are moving towards it. We are still within these three lines of defence model, and this model is kind of like thinking in silos – the business is thinking about business and compliance is thinking about compliance, not caring, for example, is the process lean, or is the customer journey really good, or whatsoever.
But within compliance, it was not really hands-on, it was more like a reviewing role after the business has already finalized with that assignment. In the end, compliance would come in, review the whole thing and we’ll say, we don’t like it and re-do it or whatsoever, and to be honest, I think that it causes a lot of frustration on both sides. It’s also not very efficient, to let people run for a month with things we can already tell them at the very beginning that this is never going to fly. So, what we had in the past month is a so-called pressure cooker sessions on the mentioned documents, but not only on those also others, where we are working together with people from different lines of defence and different tiers of, for example, compliance – I’m corporate compliance, but we also have local compliance – and together with our different business units like wholesale banking, market leaders, and so on, the local compliance representatives, the corporate compliance and others come together on a big table and then you discuss for example the policy, the requirements that are reflected in there and then you get the view from the business on it, for example, and vice versa.
We are on the table for those process documents and we are challenging them from the very beginning and also not only that, I’m not limiting my review to “is this in line with the policy,” meaning with regulations but my review goes also to say hey this process flow, for example, is not correct, or this process you’re designing might be, let’s say, in line with our policy, but a process design perspective, it is not lean and not smart. So you want to redo that, or, writing a whole section of stuff, but where is the added value? You also have to focus on your audience and what they want to get out of that document. And I think, coming back to the starting point, after having said all that, the functions are moving closer together, they see the interconnections between each other and this “I’m the first line and I’m only doing process design and I’m only doing business; I’m the second line, I’m only looking at requirements and if this process is smart or not is none of my interests” thinking in those silos is breaking up a bit, and making things more open.
How important, do you think, is interdisciplinarity going forward in your field?
I think, in my field, it’s going to be very important, I mean at least that is my opinion. Because… now more and more is very driven by digital processes, but inventing those processes, of course, takes more resources and time, because you can not just build up a tool, for example, just like that, you have to have a whole squad of people who are knowledgeable about what the tool should do and a whole squad of people that actually know how to translate that idea into IT.
But if you still keep on going with this old approach of compliance coming in the very last stage then you are already investing so much and then compliance is coming back in dashing a whole tool, so that is not efficient when it comes to managing people, money and time. It’s like you’re building some tool and the bad guys from compliance are coming in and shutting down the whole thing. We can learn from each other, there are best practices in each field. If you break apart those silos, then there are huge synergies that can spread over organisations like ING, but also between fields are not even related.
You studied law in Germany, does it help you in your current field?
Oh, absolutely! First of all, I am dealing with regulations that connects to what I did after my law degree. I somehow ended up working with taxes and then come to work with taxes in a bank. I don’t know if it is specific to German Law studies, but we deal with problems. If you see this is my issue now, then you learn that you have to look from all sides, and examine and slice and dice, and kind of bring it down, to the very essentials. That is the drill in your first year in law studies, also as a lawyer, you have a certain mindset of how to deal with certain issues, or how to deal with regulations.
I mean, you learn a lot, but you can ever know all of them. But if you at least give me a new regulation, then I know how to deal with it, and read it, how to just make my self familiar with it, and as I said, lawyers have a certain mentality, that helps a lot. Because you also learn how to, in the course of examining, what you encounter a lot especially with our mailbox, people say – I have this and this problem, please give me the answer, but they are only giving you part of all the information that you need, so you also need to dig and ask the right questions and figure out what they want. And there are certain people of course, where you know that this is definitely not the full story, and I need to dig deeper.
There are all kinds of things that you get during the education. Usually, not everybody, but usually, you are a certain type of person. Those who are into conflict avoidance don’t usually get into it. If you are in compliance, you can not avoid conflict, it comes with the job description. We are the ones who are causing the conflict, not because we mean any harm to anyone but it is just the nature of the fact that the business has other interests than compliance and you need to figure it out and deal with it without bringing it down to a personal level or anything; it’s just business.
Were your law studies quite interdisciplinary?
Yeah, that is how it is in Germany. The education is very broad. You start with criminal law, civil law, and administration law – that is everything to do with police and rights, and so on. You also learn how to build buildings – not architecturally but what permissions and stuff you need to obtain. So you start with the basics and then it gets more and more advanced as you keep going on. But you keep all three. We also have Philosophy, Ethics and History of law. Then you work at the court for some time. You have classes in the morning, and then you go to your assigned judge and get sort of one-on-one lessons with them, attending their trials and writing judgements and verdicts – practical experience.
How do History and Philosophy play into your law studies?
Personally, I think ethics and philosophy can help with a lot of things. For example, at ING at the moment, one part of compliance is called Conducts and Ethics, and they are teaching the organization how to deal with dilemmas. We had that training a week ago. And it is so interesting because you get to discuss such interesting ideas as well. Like the train is running and it can go either of two ways, there is a worker in one and the other side has five or six workers – which side do you go? [The Trolley Problem]
So we’re discussing those models which lead to a dialogue. We do it within the context of our own field – figuring out what are the excuses or problems. Saying, for example, the “the other banks do it also” – that is an excuse. In the class, we also had long discussions on the ethics of our past like in the DDR – at that time, it was okay to shoot a Jew, or a person going over the wall, but then how would you prosecute those people right now? Because back then it was law and it was permitted to do so.
Then we also talk about moral ethics – is it right to do such and such thing? Don’t I have an obligation towards society or the environment? Those are the things that even ING had initiatives about.
How important is multidisciplinary then, going forward?
I think it is important to get multi-disciplinary teams into the conversation because they bring so many interesting views and outlooks to the problem and it is only going to make the solution better.
Thank you so much, Sandra!