The Central Bank's €37.8m fine of Ulster Bank yesterday was the latest chapter in the long-running saga around the banking industry’s mis-treatment of tracker mortgage customers.

Permanent TSB and KBC Bank Ireland have already faced fines for their own breaches, while Bank of Ireland and AIB remain under investigation.

As the Central Bank fines indicate, there were rules in place to protect customers - however the mistreatment happened all the same.

According to Marion Kelly, CEO of the Irish Banking Culture Board, there are a number of reasons why a bad culture can pervade a bank.

"A lack of trust and openness, and speaking openly not being encouraged [is one]," she said. "If people afraid to speak out, afraid they’re not going to be listened to, that it might have negative consequences for them or, indeed, that it’s futile - well that’s a real indicator of a poor culture."

Other factors can be poor leadership and a focus on words over actions, Ms Kelly said.

An unwillingness to listen to other views or seek alternative and diverse perspectives, and a leading to 'group-think’, also leaves a company open to poor decision-making that can often leave the customer behind.

Overall, Ms Kelly said, a lack of accountability and a lack of consequences for poor behaviour is also a critical flaw in a business.

The IBCB is an independent industry group, backed and funded by the country’s banks, which is designed to help rebuild public trust in the sector.

It came about from revelations about the poor culture that existed in the Irish sector, including the dynamics that allowed for the tracker mortgage scandal to manifest.

"There’s a whole range of issues, and it takes time to change culture - it’s not an easy fix," she said. "In the IBCB we are in this for the long-term, and focused on trying to work with in the industry on steps which will help protect customers from major issues like this happening again."

Ms Kelly said any change will take time and persistence to achieve, with a critical first step being the banks’ ability to learn lessons from past failings.

"Accountability is absolutely key, and we in the IBCB and all of our member banks are very supportive of the introduction of an accountability regime here," she said. "It think that would be a really strong indication of the commitment of the industry to change."

Those in leadership positions in banks also have a crucial role to play, she said, as they should make expectations around behaviour and best-practice clear to everyone in the company.

People in banks should also feel able to speak up when they see something being done wrong - or identify an area where things could be improved.Meanwhile she encouraged banks to seek a wide variety of views when setting out plans for the business.

"The views of customers, and of staff, are really what drive the agenda of the IBCB," Ms Kelly said. "We ask staff, we ask customers, what they think need to change and look to put those into action with our member banks."