Story 87

Self-Investigation as Cover-Up

Citi’s CEO stated in a public interview that Citi doesn’t need policies to tell us what bad behavior looks like. Meanwhile, the once comprehensive Ethics and Harassment policy has been revised multiple times, each version narrower than the last—not to protect employees, but to limit legal liability.

Citi claims in litigation that it hires external ethics investigators “because we cannot investigate ourselves.” Internally, senior Citi lawyers investigate entire management teams for coercion and unfair practices—and find nothing. Self-investigation isn’t about accountability. It’s about control of the narrative. The best way to bury problems is to investigate them yourself.

Managing directors are hired from outside to help Citi “figure out what needs to be done.” They don’t know what needs to be done. But they will eliminate the people who do, while consolidating their own positions. Institutional knowledge is a threat when you’re pretending at reform rather than enforcing it.

One senior managing director told me directly that they refuse to enforce accountability because any complaints generated could be used to terminate their own employment. Even managers know the ethics process is a weapon, not a safeguard.

This is how Citi avoids change: performative ethics replaces ethics. Investigations produce predetermined legally-safe outcomes. Policies exist to shield the company, not fix the culture. Nothing improves because nothing is designed to.

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