Should bankers swear an oath to God?

Starting next year, Dutch bank employees must swear an oath - optionally to God - promising they will perform their duties with integrity and that they will "endeavor to maintain confidence in the financial sector."

This "banker's oath" was once simply self-regulation but is now in the Dutch statute books and must be adhered to by every one of the Netherlands' 90,000 bank employees.

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The Dutch oath comes as Richard Lambert, the head of a review into banking standards in the U.K., released his findings today and rejected the need for an oath, instead calling for a new independent body to raise standards of behavior and competence in an industry left reeling by countless scandals and crises.

Lambert has spent the last five months studying banking ethics and recommended a new professional body, independent of the banks, to set new rules and guidelines for all sectors of the banking industry.

So, who's got it right? Should an oath be required? Or is an independent body with a new set of rules enough to ensure integrity?

(Read more: Want to be a banker? Pass integrity test first)

Dutch courage

In the aftermath of the global financial crisis of 2008, the Dutch Banking Association (NVB) published the Banking Code. The code laid out the principles by which Dutch banks should conduct and came into effect in January 2010.

NVB Chairman Chris Buijink said that the original code was reviewed by an independent commission in 2012. It discovered one problem: While banks had abided by the code, no one outside the industry knew about it.

So the new code, with the banker's oath, seeks "to engage much more in the public debate and show the public and stakeholders the things banks are doing and the contributions banks can make to society," Bujink explained.

Laura Spence, Professor of Business Ethics at Royal Holloway, University of London, said the Dutch response was an attempt to make the banking profession similar to medicine and its Hippocratic oath.

"They are really trying to professionalize the industry and bring the kind of levels of integrity, and expectation around integrity, in line with other of the more established professions," Spence told

Culture differences

Spence said that the Dutch need to introduce an oath, compared to the British response of an independent body, was down to cultural differences.

"On the Dutch banking association's web page, it highlights the social role of banks and the need to make sure their actions are in line with society's expectations," she said.

Spence emphasized that the Netherlands had grasped the fact that self-regulation and voluntary approaches towards banking conduct were not enough and that rules needed to be enforced.

That also comes across in Lambert's paper, where the need for an independent body will monitor the sector and "banks will have to commit publicly to meeting the standards and make a public report each year on how they are doing."

(Read more: Banks 'paying for sins' pre-crisis: RBS)

Lambert's proposals seem to also take a rather top-down approach to standards of conduct, with the paper emphasizing that the new body would work "with the banks and building societies to define standards of conduct and assessing how well they are doing at meeting the standards against relevant benchmarks."

Bujink said that the Netherlands code was based on ensuring openness across all levels of the banking sector, so that if a low-level employee saw something that violated the code, they would feel "empowered" to speak out.

"We feel that it is important to have an open culture where people feel free to challenge ideas and people should be invited to speak up. You should not have a culture where you have a supreme leader that surrounds itself with clones."

Will either work?

Regarding the Dutch model, Spence said "It looks like an honest attempt to try to change the culture, whether it works is unclear." We won't know how the code will work until we have seen how it responds to people who violate the oath.

Will banking regulations lift US economy?
Will banking regulations lift US economy?

Rosamund Thomas, director of the Center for Business and Public Sector Ethics in Cambridge, said that there was clearly a gulf between the Dutch response and that of other countries.

(Read more: No bank too big to indict, US attorney general says)

"The U.K. and European proposals for improving banks deal largely with legal and financial regulations and less often with how to change culture and behaviour including ethics – although individual banks, such as Barclays, are purporting to upgrade their ethical standards," she said via email.

Thomas instead recommends proposals for how best to instil ethical behaviour in banking is to teach the subject in business schools with graduates taking a "Hippocratic Oath"

In a recent book on business behaviour, Thomas wrote a chapter on the lack of ethics in the banking sector.

"It is no excuse for leaders of banks and other financial institutions involved in the financial crisis of 2007–2010 to continue the practices which led to the global collapse, " she wrote.

"Nor is it an excuse to believe that only the 'will' for ethical reform exists, but not the concrete steps to achieve such improvements."

—By CNBC's Kiran Moodley. Follow him on Twitter @kirancmoodley