(Reuters) - In the aftermath of the 2008 financial crisis, the banking industry sought to address an ethics crisis with surveys, town hall meetings, appointments of overseers and mechanisms for employees to report malfeasance.

Now, the high-pressure sales scandal at Wells Fargo & Co WFC.N provides more evidence that large U.S. banks may have little to show for the effort.

Bank consultants say tens of millions of dollars are spent each year on initiatives to build a culture of integrity, partly at the urging of regulators such as the Federal Reserve Bank of New York and the U.S. Office of the Comptroller of the Currency.

Octavio Marenzi, co-founder of Opimas, a management consultant that focuses on the finance industry, said banks have spent a lot of money researching their culture and updating ethics handbooks - with little impact.

“A lot of what the banks are doing are superficial attempts,” said Marenzi. “It’s more window-dressing than anything else.”

The continuing spate of scandals reinforces doubts about the effectiveness of such efforts. Wells Fargo’s debacle - involving the creation of as many as 2 million accounts without customers’ permission – is only the latest black eye for bankers.

Other recent lapses have included widespread rigging of benchmark interest rates by traders at several banks; reports that JPMorgan Chase & Co JPM.N hired children of high-ranking Chinese officials to curry favor; and allegations in a London court that Goldman Sachs Group Inc GS.N bankers hired prostitutes for officials at Libya's sovereign wealth fund to win business.

Wells has also previously faced accusations of discriminatory mortgage lending practices from local and federal authorities. Wells, which has denied the accusations, reached a settlement with the U.S. Department of Justice in 2012.

A FEW BAD APPLES?

Earlier this month, Wells reached a $185 million settlement with the U.S. Consumer Financial Protection Bureau and the Los Angeles City Attorney over abusive sales tactics involved in the creation of bogus customer accounts.

In a statement, Wells Fargo spokesman Mark Folk said the bank takes responsibility for customers receiving products they did not request.

Wells Fargo CEO John Stumpf testifies before a Senate Banking Committee hearing on the firm's sales practices on Capitol Hill in Washington, U.S., September 20, 2016. REUTERS/Gary Cameron/File Photo

“Wells Fargo’s culture is committed to the best interests of our customers, providing them with only the products they want and value,” Folk wrote.

Workers have described a pressure-cooker atmosphere where they risked losing their jobs if they did not hit unrealistic sales targets. They say this pressure defined working for Wells Fargo and directly led to widespread fraud in the opening of bogus accounts.

Wells Fargo officials have countered that problems were isolated to a relatively small number of workers.

Lawmakers who questioned Wells Fargo Chief Executive John Stumpf at a heated Senate Banking Committee hearing last week were unmoved by this explanation, particularly in light of the bank’s firing of 5,300 workers over what it described as improper sales.

“Is it normal for 1 percent of a business unit to be fired over fraud?” Republican Sen. David Vitter asked.

Democratic Sen. Jeff Merkley later asked a panel of government officials who regulate Wells Fargo or were involved in the settlement why Stumpf attributed the problem to rogue individuals rather than a pervasive culture or structural incentives installed by bank executives.

“It’s inconsistent with our findings,” responded Thomas Curry, U.S. comptroller of the currency.

On Tuesday evening, independent directors on the bank’s board said they would pursue their own investigation and claw back $41 million worth of previously granted stock awards from Chairman and Chief Executive John Stumpf, who would also forego his salary as the directors’ probe continued.

In a statement, Lead Independent Director Stephen Sanger said directors would “take all appropriate actions to reinforce the right culture and ensure that lessons are learned, misconduct is addressed, and systems and processes are improved.”

REDOUBLED EFFORTS

Morgan Stanley MS.N CEO James Gorman has said that a creating a culture of integrity is among his top priorities. JPMorgan CEO Jamie Dimon said in the bank's 2014 annual report that his firm needed to "redouble" efforts to reform its culture after making "a number of mistakes - some of them quite painful and costly - over the last several years."

The mistakes included a $13 billion deal with the U.S. government to settle allegations of overstating the quality of bad mortgages to investors. Since then, JPMorgan launched an examination of its culture that included interviews between senior executives and over 16,000 employees.

Citigroup Inc C.N also recently launched an internal video series in which senior executives discuss how they handled business decisions in gray areas of ethics.

The bank also lets employees know when colleagues are dismissed for inappropriate conduct, such as in 2014 when it dismissed 12 employees after finding fraudulent loans in Mexico. This was communicated to the firm in a memo from CEO Michael Corbat.

For the first time this year, Morgan Stanley will ask risk and compliance officers to evaluate so-called “material risk-takers,” such as bankers and traders. This feedback will play a factor in promotion and compensation decisions.

European bank executives are also focused on promoting a culture of honesty. Deutsche Bank AG DBKGn.DE CEO John Cryan has spoken publicly about the German lender's need to change, while former Barclays PLC BARC.L CEO Antony Jenkins was so focused on improving the British bank's culture that some employees dubbed him St. Antony.

The banks declined to comment for this story.

MEASURING CHANGE

As they have embarked on these cultural-change campaigns, banks have struggled with how to measure progress. Bankers who spoke to Reuters on condition of anonymity mostly acknowledged their institutions have more work to do.

Some have started running employee opinion surveys with questions such as, “What makes you proud to come to work?” and “What impedes the way you do business?” Personality tests can also examine how employees think about risk and how their personal values affect business decisions, said Ernst and Young’s Clive Martin, who works with banks on culture issues.

Banks are also looking for signs that an employee might engage in bad behavior. For example, if a trader who frequently hits risk limits, misses compliance training, or doesn’t take a mandatory two week holiday that is imposed to catch fraud, it could be a red flag, consultants and bank lawyers say.

The New York Fed, which has held symposiums on changing the culture of Wall Street, has suggested creating a database of bank employees who were dismissed for bad behavior.

Even with all these methods and tactics, some experts see little fundamental improvement.

“You can tell banks to be good, and the Fed tries hard - it holds gatherings and seminars, gets us academics in and we talk about stuff,” said Shivaram Rajgopal, a professor at Columbia Business School who has researched corporate culture. “The less cynical perspective is, maybe it’s hard to move the needle.”