Are the low-level employees more to blame, or the managers? Were both in a conflict of interest situation?

Wells Fargo case study

In 2016, Well Fargo was fined a combined total $185 million for fraudulent activity, and CEO John Stumpf resigned. Between 2011 and 2016, approximately 5,300 employees were fired for fraudulent sales practices. Sales quotas were eliminated effective January 1, 2017.
Ethical Insight
Wells Fargo has a fiduciary duty to treat its customers fairly. The bank offered many different services to its customers. But the bank’s management set unrealistically high sales goals for its employees, encouraging many employees to game the system. If a customer bought one service, employees were urged to “cross-sell” several more. “Eight is great” was the company mantra. The only way that Wells Fargo employees could meet their unrealistic sales targets, and thereby keep their jobs, was to make up accounts that customers had not requested and often didn’t even know they were being charged for. Employees fabricated millions of fraudulent accounts in order to keep their bosses happy and remain employed. It was a classic conflict of interest.
Case Questions
1. In what ways does this case study demonstrate conflict of interest?
2. In what ways did company culture and compensation at Wells Fargo encourage incentive-based fraud (gaming)?
3. Although Wells Fargo attempted to curb fraudulent activity with an ethics workshop and change in compensation structure, the company continued to find fraudulent accounts being opened by employees. Why do you think this continued to occur? What do you think Wells Fargo could have done to better curb fraudulent activity?
4. Are the low-level employees more to blame, or the managers? Were both in a conflict of interest situation?
5. Many employees admitted that they knew what they were doing was wrong but continued to open fraudulent accounts. Do you think their actions were in any way ethically justifiable? Why or why not? If you were in their position, what would you have done? Losing your job is tough. Losing sleep at night because you knowingly ripped off a customer might be tougher. How would you resolve such a conflict of interest?

Partial List of Possible Resources to Use in Addition to Videos/Documents on course website
Wells Fargo Fined $185 Million for Fraudulently Opening Accounts

The Wells Fargo Fake Accounts Scandal Just Got a Lot Worse
http://fortune.com/2017/08/31/wells-fargo-increases-fake-account-estimate/
Former Wells Fargo Employees Describe Toxic Sales Culture, Even At HQ
https://www.npr.org/2016/10/04/496508361/former-wells-fargo-employees-describe-toxic-sales-culture-even-at-hq
Wells Fargo Warned Workers Against Sham Accounts, but ‘They Needed a Paycheck’

Wells Fargo’s pressure-cooker sales culture comes at a cost
http://www.latimes.com/business/la-fi-wells-fargo-sale-pressure-20131222-story.html
Wells Fargo is eliminating retail sales goals after settlement over aggressive tactics
http://www.latimes.com/business/la-fi-wells-fargo-sales-20160913-snap-story.html