Published on Global Ethics Day, this episode of the FM podcast is the continuation of an occasional series focused on ethics and called Beyond the Code. That means taking a detailed look at part of the CIMA Code of Ethics.
Xose Lumor, manager–Advocacy and Professional Ethics, speaks with Fraser Simpson, a strategy and governance leader, on why ethics should be embedded in decision-making rather than treated as a compliance exercise. The conversation explores how leaders can navigate uncertainty, balance competing priorities, and make better decisions in complex organisations without sacrificing trust or accountability.
For more information, visit the CIMA Code of Ethics home page.
What you’ll learn from this episode:
- Why ethical considerations belong at the centre of business strategy.
- How leaders can make sound decisions when faced with uncertainty and competing demands.
- The role governance plays in improving decision-making across an organisation.
- How to build trust while navigating difficult strategic choices.
- Practical ways to embed ethics into day-to-day leadership decisions.
Play the episode below or read the edited transcript:
— To comment on this episode or to suggest an idea for another episode, contact Neil Amato at Neil.Amato@aicpa-cima.com.
Transcript
Xose Lumor: Hi, there. My name is Xose Lumor. I am the Manager, Advocacy and Professional Ethics here at CIMA.
My role is to manage professional conduct cases where members are accused of misconduct, and I also develop ethics content on behalf of CIMA. That is very much why we’re here. I want to welcome you to another episode of Beyond the Code, the series where we explore ethics, professional conduct, and the real-world challenges faced by CIMA members across the accounting and finance profession.
This conversation is all about unpacking the nuances behind questions like, what does ethical decision-making look like in complex organisations, and how do good leaders make good decisions under pressure? In today’s episode, I’m joined by a guest whose current work might just help us unpack all of that. Today, I will have the pleasure of speaking with Fraser Simpson, associate director–Strategy at the Wellcome Trust. Fraser has an incredible breadth of experience.
His current work sits at the intersection of strategy, governance, and enterprise decision-making in complex global organisations. In short, he focuses on how institutions make high-stakes decisions, aligning purpose, performance, and people, so organisations can operate at pace without compromising judgement or losing trust. Together, we’ll explore how organisations can fuse ethics, governance, and strategy at the executive level. We’ll also discuss decision-making in complex global organisations, in particular, how institutions make high-stakes decisions, as well as discussing the ethics of decision-making more generally. With all that in mind, let’s head beyond the code. Hi, Fraser.
Fraser Simpson: Hi, Xose. Thanks for having me.
Lumor: Can you tell us a bit about yourself and what you do?
Simpson: Yeah, of course. I’m currently associate director of strategy at the Wellcome Trust, which is one of the world’s largest global philanthropies. Before that, I spent a number of years building Wellcome’s integrity function, so dealing a lot in legal and ethics. Really, my work has sat across strategy, governance, ethics, legal, decision-making, and most often with boards and CEOs facing really complex choices.
Lumor: Given all of that, what would you say is, I guess, the thread that runs through all of your work — because that’s quite a broad range of work?
Simpson: It’s been a really broad array, and I think the common thread really is around using human judgement to improve decision-making. We talk a lot about strategy, we talk a lot about technology, process. But organisations, in my experience, ultimately succeed or fail really because of the quality of the decisions people make. You can have the best strategy in the world, but it doesn’t deliver itself.
You can have the most coherent ethics policy in the world, but it doesn’t happen by default. People have got to interpret those, they’ve got to test themselves, they’ve got to challenge themselves, and really, they’ve got to make choices under pressure in moments that matter, and that’s where human judgement comes in. How is it that organisations make better decisions when the answer isn’t obvious? I see that as being the defining leadership challenge for this era.
Lumor: There is one thing that you mentioned that I wanted to touch on and use it as, I guess, a starting point today. You mentioned one of the areas your work touched on is ethics, and I suppose to help our audience understand what we’re going to be talking about today, I suppose we can start with the basics. What do you think of when you hear the word ethics?
Simpson: It’s one of those words that a lot of people hear and they think about rules, compliance, misconduct, and all those sorts of scary, but really quite important things, they really matter. But I see ethics as being something much more practical. For me, it’s about how we navigate really difficult choices and trade-offs where there isn’t an obvious right answer. In my experience, most senior leaders are rarely choosing between binary options of good and bad, but what they’re trying to do is to navigate shades of grey, they’re trying to choose between competing priorities, between competing risks, competing responsibilities. How I see ethics is human judgement in action, it’s what helps us to make responsible choices when certainty isn’t there.
Lumor: I believe you described your work as sitting at the intersection of strategy, governance, and ethics. Could you elaborate a bit more on this?
Simpson: It’s an exciting Venn diagram to find yourself in the middle of. I see, actually, strategy, governance, and ethics as being intrinsically connected, they’re all sides of the same coin. The way I like to think about it really is that strategy asks questions like where are we going and how will we succeed, or in my world, how will we have impact? Governance asks, how are decisions made and who’s going to be held accountable for those?
Then ethics comes in and really says, well, are those decisions responsible, sustainable, worthy of our trust? I guess what I’m getting at is I think they’re all three different lenses on the same challenge, which is how do we make good decisions that stand the test of time, of scrutiny, and of consequence. I feel that the stronger organisations don’t separate out those conversations, they bring them together, it’s not separate strategy, ethics, governance conversations, it’s one coherent conversation that brings those together.
Lumor: Do you think it’s common for organisations to treat ethics as separate from strategy, rather than being embedded within it, if that makes sense? If so, why?
Simpson: I think that’s right. I think many organisations, actually, don’t necessarily think about ethics. A lot wed themselves in the sort of what I consider to be a slightly outdated view of compliance. If we comply with the law, then all is good. Actually, I don’t think that’s sustainable, and increasingly, I don’t think it is sustainable in our world where we’re more proximate to scrutiny and challenging in non-legal ways.
But where organisations do think about ethics, quite often, they treat that as separate from strategy, and unintentionally. I think, like I said in the last question, ethics so often sits in that compliance risk and legal world, while strategy, on the positive side, sits with growth and impact and delivery, and performance, and all those positive things we’re trying to achieve. The risk there, then is ethics feels a bit more like a handbrake on strategy rather than an enabler of it, rather than something that improves it and drives it forwards. If that’s the case, by the time the ethical judgement gets into the decision-making room, the direction’s probably already been set. I think that’s problematic.
You see similar sorts of risks with AI, where organisations move quickly to adopt new AI tools because they’re going to make us all more efficient. But it’s not just about that strategic question, can we be more efficient? There’s the ethical piece in there at the same time. What are we trying to achieve? Who might be affected by this, whose voice is missing? Other questions like what trade-offs are we making? What voices are we missing in the room? For me, all of those say ethics shouldn’t be something that’s layered on top of strategy, this is something that’s absolutely central to it.
Lumor: I suppose to that point, then, at board or executive level, what does it actually look like when ethics is genuinely integrated into strategic decision-making rather than being an afterthought?
Simpson: It’s getting away from ethics being a tick box. Have we thought about the ethical questions? It’s actually driving this as being better questions being asked earlier at an exec and a board level. It’s the right people being involved at the earliest opportunity. We get earlier to leaders not just asking, can we do it or will this work? But they’re asking, should we do this? Who’s going to benefit from this? Who is it that is carrying the risk? Would we be comfortable defending this publicly if this was on the cover of the newspaper? Does this fit with our beliefs and values as an organisation? I think all of those are the sorts of questions that we end up asking earlier and better, and that helps shape better decision-making.
Lumor: Being that we’ve touched on a few different areas, I thought I might touch on governance just quickly. What risks exist when governance frameworks appear strong on paper, but in practice, are ineffectual in influencing real-world decisions?
Simpson: There’s always a temptation to think that having a process somehow solves everything, tick. I think the main risk here is false assurance, and I sometimes call that governance theatre, where a thing is there on paper, but it doesn’t actually have an impact. I guess that process can give the impression that a decision has been well made or thought through. But perhaps, real judgement hasn’t actually happened at all, or it’s happened outside of the room.
Examples might be, the board paper is complete, the committee actually met and made a decision, a box has been ticked on a cover sheet. But none of that actually answers whether anyone actually asked or answered the difficult questions. A tick box can prove something was mentioned, but it can’t prove that good judgement was exercised. For me, good governance needs to really sharpen that thinking and create space for challenge. If it doesn’t actually influence behaviours, then it’s theatre, not governance.
Lumor: One of the things that’s come up quite frequently already is the idea of decision-making, and you mentioned it a few times now. In large global organisations, as can be expected, decisions are very rarely simple. What makes high-stakes decision-making unique at that scale?
Simpson: Every organisation, to a degree, is unique, but at a global scale, I think decisions we’re engaging in often involve more stakeholders, they’re involving longer chains of consequence, and probably even less complete information than in smaller organisations. You might be making choices that cut across different geographies, different cultures, different legal, and regulatory environments, different time horizons, the impact of the decisions you’re making might be felt by people who aren’t in the room.
In the case of an organisation like Wellcome, they might be being felt by future generations that aren’t even born yet. I think that makes high-stakes decisions less about seeking out that perfect answer now and more about how do we surface the assumptions we’re making? How do we understand the uncertainties we’re dealing with, and making sure that we’re honest about the trade-offs that we’re making in those decisions? It’s more a question of, I guess, have we seen enough of the overall system that we’re operating in to be able to make a responsible decision?
Lumor: You mentioned trade-offs there, and I did wonder, what do complex global organisations need to consider in order to balance pace and performance pressures with the need for careful ethical judgement when making decisions?
Simpson: So often, pace and judgement are presented as opposites that are really in tension with each other. You either have pace, or you have slow judgement. But I don’t think that’s right, I don’t think they have to be in tension. I think the burning question for us all, is, how do we maintain good judgement at speed? How do we become the seat belt that enables us to go faster but safely? Organisations, to my mind, they need to avoid the moment where pace becomes momentum. Pace isn’t a bad thing, pace is a good thing, we want to do things quickly. The challenge is when pace becomes momentum, and momentum starts taking decisions for you, so decisions become self-justifying.
I’m not arguing at all that every decision needs a heavy process, far from it, but I think we need to get better at understanding which decisions are important enough to need a deliberate pause, to create that space for judgement and thinking. In practical terms, that’s as simple as asking ourselves, what do we know? What are we assuming? Who might see this differently to us? What sort of things might stop us and make us change course? Those are all really straightforward questions, but ones that sometimes it’s hard to create the space to ask ourselves because profit pressures, market pressures are driving us forwards. The answer isn’t more bureaucracy, but it’s better judgement in those moments that matter.
Lumor: On that point, you’ve worked closely with boards and CEOs. What are some of the most common tensions leaders face when trying to make good decisions?
Simpson: Lots of different tensions. But as I said earlier, I think leaders are rarely choosing between a binary good and bad option. More often, it’s competing priorities, whether that’s short-term delivery versus long-term trust, whether that’s between doing something at pace as opposed to doing it in a more inclusive way, whether that’s between doing something consistently, as opposed to taking into account individual context every time, whether that’s between ambition and taking risk. I think there are so many tensions in there. The modern world is cranking them up.
AI is a great example of something that’s amplifying some of those tensions. AI is a tool that can really help leaders, I mean, all of us, but leaders in particular move faster, but it can also then push us into a situation where flawed assumptions that we bring actually start to look more authoritative than they are, and we run with them. I think good leaders don’t pretend the tensions don’t exist or try to make them disappear, but they try to make those tensions visible. They try to bring them out in their leadership teams. They try to create honest conversations around them and create the conditions where actually a diverse group can bring their perspectives to contribute towards better human judgement.
Lumor: A question I’m very curious about personally. What would you say differentiates organisations that make consistently good decisions from those that struggle even when possessing similar resource capabilities?
Simpson: That’s an interesting question. I guess there’s a couple of elements. Good decisions might, I guess, be luck. But doing it consistently isn’t. I think it’s rarely having the smartest people or the most resources. We’ve all seen big cutting-edge organisations make bad decisions. I don’t think it’s that. I think what it is is around the organisations that intentionally create conditions around making important decisions. I think strong organisations are intentional around building habits that allow people to think well together. They’re clear on who’s making decisions. They’re clear on really being open to challenge and encouraging people to make challenge. They’re clear around making sure people have access to the relevant information in order to make decisions that they bring a real diversity of perspective into the decision-making room, really getting away from groupthink, but more than that, really bringing a diversity of perspectives together.
Focusing on reflection and learning and trust after the event follow-up reviews, what went well, what went badly, and being able to do that honestly. I think from my experience, those that have built those sorts of ways of working help their smart people think well together, as opposed to smart people going off and doing their own thing. I think that’s where it works well. I think those that struggle allow their talented people to go off and operate in systems that reward other things that reward speed or certainty or getting stuff done quickly rather than rewarding good judgement.
Lumor: One of the things we talk about on this podcast as part of this series is the various things that can impact organisational culture. I wondered what your thoughts were on how leadership impacts an organisation’s culture, but specifically, when it comes to ethical decision-making.
Simpson: Yeah, and I think it’s so important. It’s often talked about in terms of tone from the top. I think tone from the whole organisation is important, but particularly from the top. I see leadership really shaping ethical culture through human signals that it sends right across the organisation. Colleagues, people in organisations, they watch closely what leaders listen to, reward, tolerate, ignore challenge.
If leaders say that their values matter, they write them on the wall of the office, they’re in the handbook. But then they act in a different way. They reward delivery at any cost. That sends a really clear signal to an organisation that actually ethics and values don’t particularly matter. Whereas, if a leader very obviously visibly, audibly welcomes challenge is authentic enough that they can admit that they don’t know the answer, that they admit uncertainty. They take consequences and impacts on people really seriously. That sends a really different message. That sends a message very loudly that actually ethics and doing the right thing in moments that matter is something that’s really important to the organisation. I think it’s around those signals that show that cultures, what people learn through experience will be safe and valued and expected in practice from them.
Lumor: When stakes are high and information is incomplete, which let’s face it, is often the case.
Simpson: Always. Yeah.
Lumor: How can leaders ensure they’re still making ethically grounded decisions?
Simpson: As we jokingly said, always incomplete information in the question. I mean, the first step is to admit that it’s totally normal to have incomplete information. That’s as much in work as it is in the rest of our lives. I think it’s important that we also acknowledge that ethical judgement doesn’t require certainty. Ethical judgement is about making choices where there are shades of grey, where there isn’t an obvious outcome.
It requires that discipline, the intentionally creating and preserving the space to pause and to think. I think that’s to first of all, create the space to say, Well, what is it we know? Equally, what don’t we know, and what assumptions are we making? Then it gives us the space to then go a bit deeper and to say, Well, who could be affected by this decision? Importantly, whose voices are missing from the table? What else would change our view? I think those questions matter because when we’re under pressure, we often suppress concerns too quickly. Those voices that are closest to the impact of a decision and most often furthest from the decision-making table aren’t always audible.
I think challenging ourselves as to who’s missing enables us to amplify those voices. The goal, as I said before, isn’t getting to a perfect answer, it’s how do we get to the most responsible decision we can make in the moment. If you adopt that mindset, then I think you can happily get into making the best decision you can in the circumstances.
Lumor: Fraser, it’s been amazing. Thank you so much for taking the time to talk to us. Your work is brilliant and no doubt our audience will thoroughly enjoy listening to this conversation.
Simpson: Oh, well, thanks so much. It’s been a real pleasure, and really hope that people get something out of this.
Lumor: That’s been a thoroughly enjoyable conversation. Thank you again to Fraser for joining us. If you are listening and want to get more information about ethics at CIMA, please visit CIMA’s ethics webpages. A link will be provided in the show notes. There, you’ll find a wide range of helpful tools and resources that you can follow to learn more about these subjects here. That’s it from us. My name is Xose Lumor, and we’ll be back soon with another episode of Beyond the Code.
