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ARTICLE 1

Critical Elements of an Organizational Ethical Culture


Thursday, February 18, 2006

By Amber Levanon Seligson and Laurie Choi of the Ethics Resource


Center in Collaboration with Working Values

Critical Elements of an Organizational Ethical Culture


In the study that follows, the Ethics Resource Center has identified three types of ERAs
that have an especially great impact on outcomes expected of an ethics program. ERAs such
as setting a good example, keeping promises and commitments, and supporting others in
adhering to ethics standards can have a powerful influence on building an ethical culture.
However, they can also be difficult to achieve if the organization's efforts are anything
less than 100%. Therefore, to the extent companies can use this research to help focus attention
of leadership on the critical need to improve these ERAs in their own organization, the better
chance the organization has to reach its program goals.

Working Values is proud to have been a sponsor of this additional research undertaken by the
Ethics Resource Center into the NBES. We all share the same goal of having every company
put forward the most effective ethics program possible.

In the 2005 National Business Ethics Survey® (NBES) study, the Ethics Resource Center
(ERC) presented research regarding elements of ethics and compliance programs, the ethical
culture of organizations, and outcomes expected of an ethics and compliance program. 1
Findings from NBES 2005 suggest that organizations should use their ethics and compliance
programs to foster a culture committed to ethics throughout the organization. These findings
were based on measures of ethical culture that included the "Ethics Related Actions" (ERAs) of
top and middle management, supervisors, and coworkers.

ERC's findings suggest that organizations should focus training not only on informing employees
about compliance with regulations, but also on encouraging employees to behave in a way that is
conducive to a strong ethical culture. This paper presents new analysis on whether specific ERAs
have a greater impact on outcomes than others. In addition, ERC analyzes whether ethics
training is more useful to senior employees than junior employees.
This research is useful for organizations in several ways. The findings emphasize the notion
of actions speaking louder than words. By identifying which ERAs have a greater impact,
organizations can better target training to promote a culture committed to ethical conduct
in the workplace. Organizations that dedicate substantial resources to the communication of
ethical values may find that resources are better spent encouraging leadership to set a good
example of ethical behavior, establishing organizational trustworthiness in keeping promises,
and helping employees to make ethical decisions. The findings are also instructive in pointing
out how organizations can tailor their ethics training to different levels of employees. Upper
management may need less emphasis on how to handle ethical dilemmas and more emphasis on
how to engage in ERAs, while junior employees may need instructions on how to proceed when
faced with ethics challenges.

The Impact of Ethics Training Among Levels of Employees


Having shown that not all ERAs or levels of employees have an equally important impact
on outcomes, we now turn to the third second research question in this paper: Does formal
ethics training have the same impact on all levels of employees? Specifically, does training help
all employees feel more prepared to handle ethically challenging situations or does it help some
more than others?

Ninety-eight percent of senior managers who have been trained feel prepared to handle risk
compared to 91 percent of those who have not been trained, which is only a 7 percentage point
difference. However, as one moves across management levels, the gap becomes more
prominent. For example, 79 percent of non-managers who have been trained feel prepared to
handle risk, compared to 58 percent of non-managers who have not been trained. This is a
21 percentage point gap, and the difference is statistically significant.

Conclusion
This study suggests that certain Ethics Related Actions (ERAs) have a greater impact on
outcomes expected of an ethics and compliance program than others. Specifically, this
research shows that, across all employee levels, setting a good example, keeping promises
and commitments, and supporting others in adhering to ethics standards have the greatest
impact on outcomes. Communicating the importance of ethics is less frequently associated
with improved outcomes, which could be due to employee perceptions that "living one's values"
or "walking the talk" is more credible than only talking about ethics. Ethics and
compliance programs are more effective when employees throughout an organization act to
promote, rather than just talk about, ethics.

This study also reveals that ethics training is more helpful in preparing junior level
employees to handle ethics situations than senior ones. This does not mean that
organizations should abandon training programs created for upper echelons of management.
Perhaps senior managers develop ethical decision making skills through their professional
experiences moving up the organizational hierarchy and, therefore, training has a different
impact on junior employees who are not as familiar with ethics issues. Upper management may
benefit from issue or topic-specific training that helps raise their awareness of particular
types of misconduct; however, comprehensive training programs that strengthen ethical
decision making skills may be more beneficial for junior employees.
ARTICLE 2

Ethics expert: Train workers on reporting misconduct


Friday, January 16, 2004
Washington Business Journal - By Karen E. Thuermer (an Alexandria-
based freelance writer)

Stuart Gilman, president of D.C.-based Ethics Resource Center (ERC), has a passion for business
ethics.

He was interested in the subject long before it became a hot topic when regulators charged
WorldCom with fraud in 2002. The company admitted it hid almost $4 billion of costs, which
forced the largest bankruptcy ever.

The Securities and Exchange Commission said in its civil lawsuit the scheme was directed by
senior management and allowed WorldCom to fraudulently report 2001 cash flow of $2.4 billion
rather than its actual loss of $662 million.

Similar stories showed the ugly consequences of ethical lapses at other high-profile companies
such as Enron and Tyco.

To help raise an awareness that might prevent business scandals and misconduct, ERC recently
surveyed 1,500 American workers on those issues and distributed its findings to more than 900
business school administrators and academics.

Gilman spoke to contributing writer Karen E. Thuermer about efforts today to instill a sense of
ethics in employees at all levels of a business.

 When people hear about "ethics" in organizations some may think of taking office
supplies, while others think of accounting fraud like Enron or WorldCom. Why is ethics
important today and what really constitutes an ethics scandal?

People focus on the taking of office supplies as trivial. But organizations that close a blind eye to
minor pilfering can suddenly find other ethics situations escalating from the bottom to top, such
as what happened at Enron.

People must act responsibly to their peers, organization, stakeholders, stockholders and
customers.
Corporations are recognizing that as part of compliance they need to go beyond the law because
bad ethics practices can ultimately affect entire business sectors. Look at what happened to
Arthur Andersen.

 Are there situations where businesses need to be especially concerned about ethics today?

Organizations undergoing transition such as mergers and acquisitions find themselves in


awkward positions because of a vacuum in leadership.

Corporate executives must also realize they cannot be passive leaders. Being a nice person is not
enough.

In addition, board of directors must step up to the responsibility to make certain ethics systems
are in place.

 What are the key findings in the ERC 2003 National Business Ethics Survey? Since the
survey is the third done in the last decade, can you tell if ethics is getting better or worse?

Employees found ethics practices better in 2003. But perhaps this is because of the Enron Effect,
which will evaporate in two years. Only 20 percent of employees see ethics getting worse.

We found that people under 30 and relatively new to an organization are most vulnerable.

They are far less likely to report misconduct than people who are older and more established
within the organization. This is especially a concern since today more people are retiring than are
going into the work force.

These people need training and effective communication strategies to make sure they know their
company is taking them seriously. They need a place to go when they need to ask the question
about ethics practices.

 Are certain industry sectors more vulnerable than others?

Many industry sectors are looking at the meltdown of the Tycos and companies within the
mutual fund industry. They are saying they are glad the focus is not on them.

But all sectors are vulnerable and not exempt. All industry sectors need to be ethical because it is
the right thing to do.

Does the economy play a large part in how ethics is perceived within an organization?
Does technology make us more ethical or less?

Concerns about the economic turndown and how a company lets people go lead to issues of
illegality and ethics.
Human resource departments are feeling the pressure as are accountants and auditors.
Accountants are told to cover up figures, that the company will make the difference in the next
quarter.

Technology has advantages in that it allows us to communicate more effectively. But with that
comes e-mails that are accessible and may be distributed.

 What can or should companies do to ensure ethical behavior?

Talk about ethics, act ethical, keep promises and be upfront about ethical obligations to
customers.

[The number of] employees who felt pressure to perform unethical conduct is reduced by 75
percent when a leader within a corporation fulfills all four of these dimensions.

Therefore, it is critical that senior leadership sets high standards. If they do not, they undermine
the ability of employees to both respect and understand what ethics is in their organization.
Unfortunately, this responsibility often falls on the HR department, thereby making employees
feel the company has no coherent ethic.
ARTICLE 3

Ask these questions when you are building your


organization’s ethical foundation
Friday, October 24, 2008
Memphis Business Journal - by Barbara Richman

The public has witnessed numerous cases involving organizational scandals and questionable
ethical practices in recent years. Companies such as Enron and WorldCom have ceased to exist
because of the pervasiveness of unethical conduct. Other organizations, both large and small,
have been subject to public scrutiny and legal actions as a result of questionable activities.
Reputations have been ruined, individuals have been prosecuted, and employees, stockholders,
retirees and customers have been appreciably harmed by various types of unscrupulous conduct.

In recent weeks, the nation, as well as much of the world, has found itself in the midst of a
financial crisis of a previously unimaginable magnitude. As these events and their impact on our
economic stability unfold, questionable ethical decisions and practices have become one aspect
of the current focus. Although individuals have limited ability to impact the government’s
attempts to rebuild monetary confidence, we can play a more active role in examining our
personal actions and the influence that we have on ethics within our organizations.

Posing questions on ways to build an ethical foundation within the organization provides one
means of focusing on a subject that is broad and can be addressed from different vantage points.
The following are among the questions that can be asked in pinpointing these considerations:

1. Are values and other guiding principles incorporated in the organization’s culture? Do
employees at all levels of the organization share and act on these beliefs and articulate them in
discussions with others? One key indicator is whether leadership “walks the talk” on an ongoing
basis through communications and actions that reinforce these values. If organizations follow
other courses of action, the resulting lack of trust will be greater than if there had been no stated
principles.

2. Has attention been paid to policies, procedures, practices and expectations to ensure that they
are in alignment with organizational values and to determine if there will be a commitment to
enforcement? Prior to implementation, management should examine policies and other standards
for alignment with values and for assurances that they will be consistently enforced, even if
violations involve one of the organization’s top performers or executives.
3. Does the organization have ethics policies in place and provide training or other
communications to increase understanding? While a number of policies address the subject of
ethics in a general manner, the handbook should also incorporate specific policies that establish
expectations for integrity and adherence to ethical standards of behavior, such as conflicts of
interest, business gifts and gratuities, and disclosure of confidential information.

4. Does the organization comply with applicable laws? Although legal requirements are only one
part of the overall ethical landscape, adherence to laws is a requirement that establishes
minimum standards for organizational behavior.

5. What checks and balances are in place to avoid potential ethical missteps? Whereas these may
differ depending on the size and nature of the organization, there should be an emphasis on
instituting various preventive measures and types of oversight. Examples include making ethics a
pertinent factor in decision-making discussions, developing processes for accountability, and
hiring an ethics officer or identifying another individual with responsibility for organizational
ethics, compliance and business conduct programs.

6. Is personal accountability an expectation of the organization? If so, employees at all levels


should understand that they will be held accountable for their actions, both positive and those
that require improvement, and that those actions will be taken into consideration in making
employment decisions that include counseling, discipline, promotions and performance
evaluations.

7. Am I or the organization applying rationalizations, an ends-justify-the-means approach, or


similar reasoning to justify actions that have been taken? One of the easiest paths that we can
take is to attribute our actions to rational motives without first analyzing the facts. For example,
if the frequently used rationalization, “everybody is doing it,” is applied, individuals may tend to
generalize in terms of numbers to justify questionable actions and overlook necessary facts.

8. Does the organization identify persons and departments that can provide assistance in
responding to questions regarding appropriate behavior? Since policies and procedures cannot
cover every “what if” scenario, employees should be able and encouraged to seek assistance
when there is uncertainty about the propriety of potential actions.

9. In making decisions, is there sufficient attention given to their impact on key stakeholders?
Potential decisions should be examined from an overall perspective that includes an assessment
of their impact on employees, customers and the public.

10. Does the organization articulate a “glass house standard” for behavior whereby the leadership
and all employees act as if others can view each action that they take? Pertinent questions, such
as the following, should be asked in introspection or of one another: How will these actions be
perceived if they are described in the headlines of a local newspaper, discussed on a morning talk
show, or used as evidence in a lawsuit? How will I respond? Will there be potential
repercussions for me or the organization? Whereas actions may comply with laws and policies
and, therefore, be technically correct, they may fail this degree of scrutiny.
ARTICLE 4

Strategies for Improving Ethical Behaviors in Organizations


April, 2006

By Gabriel Omolewu, Associate Professor of Management, Wilberforce


University

Introduction
Ethics is the study of morality. It is the value that is worth pursuing in life. It is
honorable behavior. Ethics is relative. What is honorable in one society may not be honorable
in another. It depends on several factors: world views, descriptive values and moral values. It is
a function of the environment. What one salesperson may consider being an unethical marketing
behavior, another salesperson may perceive it as an aggressive marketing strategy. Ethics can be
illustrated with the popular story of a millionaire who built an Olympic size swimming pool for
his evening enjoyment. He filled the pool with many crocodiles of different types and sizes.
His own idea of enjoyment is to watch these crocodiles swim every evening. At the completion
of the construction of the swimming pool, he invited all the elites of the city to its dedication.
As people were eating and drinking, an announcement was made by the host, over the public
address system, that if any young man was bold enough to swim across the swimming pool, he
would be given one of two things: a real estate that worths $1 million or his only
beautiful daughter in marriage. Before he finished his announcement, a young man jumped into
the swimming pool, to the surprise of everyone, swam across the pool and got out
without a single bruise on his body. The millionaire ran to him, gave him a big hug and asked
him what he would like to receive out of the two. The young man said he did not want any of
them and that the only thing he wanted was, he wanted to know the bastard who pushed him into
the swimming pool. That is ethics. The young man told the truth. He did not want any of the
two rewards promised by the millionaire because he did not, on his own, jump into the pool. He
was pushed by an unknown person. The millionaire too behaved honorably. He did not
believe anyone could jump into the swimming pool to swim across. Since somebody did, he
was still willing to stand by his words. He did not say he was not willing to give his only
daughter in marriage to a stranger.
Unethical Behaviors
The media feeds us with information of unethical behaviors in our environment revealing
the unethical social issues that demand our attention. The newspaper accounts of
unethical behaviors in business have raised concerns about business ethics which have led
to studies on their causes in organizations (Carroll, 1978, 4). These unethical behaviors
are from unsavory individuals that have no moral character. In 1961, the survey conducted by
Reverend Raymond C. Baumhard S. J., showed that there was a very high concern about
ethical behaviors.

What is an Unethical Behaviour?


The Civil Service Commission of Philippines defined an unethical behavior as any behavior
prohibited by law. In a dynamic business environment, a "large gray area" exists that makes it
difficult and unclear to distinguish what is ethical. An unethical behavior would therefore
be defined as one that is not morally honorable or one that is prohibited by the law.
Many behaviors will fall in the classification including corruption, mail and wire fraud,
discrimination and harassment, insider trading, conflicts of interest, improper use of
company assets, bribery and kickbacks, compliance procedures, ethical relations with
others, disciplinary action, fraud, illegal business donations, patent infringement and product
liability (Barrcus & Near, 1991, 12).

Unethical behaviors that stimulated interest in ethics include Watergate events, Lockheed
Scandal, the 1972 United States presidential election, illegal business donations and bribery of
foreign officials in order to induce business abroad (Carroll, 1978, 5). Today, the most common
ones are false communication, collusion, conflicts of interest, gifts and kickbacks, health services
providers' unfair practices, insider trading, discrimination and harassment, and embezzlement.

False Communications
False communications fall into various categories. They include falsification of auditor's
or controller's report or any form of manipulation that does not tell the whole truth. These
include cheating on tax returns or inappropriate depreciation schedule and wrong expenses
(Brennan Jr., Valtz, Shallenberger & Stanton, 1961, 164). Feeding the public with wrong
report of the organization's business performance to make the organization look good is
another common practice. In 2001, Enron gave wrong information about their loss because Ken
Lay, the CEO of Enron, was advised by some trusted Enron executives to report only $1.2
billion of the $7 billion in losses because it was felt that the amount could be explained
reasonably without doing more damage to the falling stock price of the company (Collins, 2007,
3). Similar to this was the case of Manville Corporation. The top management of the
Corporation suppressed, for decades, evidence which proved that asbestos inhalation was
killing their employees.

Collusion
Collusion, especially with competitors, to fix prices, is an unfair business practice today. This
could be considered stealing from customers. However, there are differences of opinion on
whether or not price fixing is stealing from customers (Brennan Jr., Valtz, Shallenberger
& Stanton, 1961, 174).

Gifts and Kickbacks


Some organizations do not allow their employees to receive gifts from clients during
Discrimination and Harassment

Discrimination involves not providing equal opportunity in employment on merit but on other

basis such as race, sex, national origin, age, religion, or any other basis not related to the job.

normal course of business. Those who do, generally provide guide lines on limitations as to the
amount an employee can receive as gift. Sometimes a buyer may request for kickbacks or
entertainment which, if not provided, may lead to the loss of the customer. An employee
frequently receives pressure from the management to behave unethically or to obtain profitable
business at any cost, which may include the use of any possible dirty tricks. The employees who
desire to be retained or promoted have no choice but to dance to the tune of the management.
This is because there were cases of those who refused to behave unethically the way management
instructed and were fired or nearly fired (Brennan Jr., Valtz, Shallenberger & Stanton, 1961,
165).

Conflict of Interest
Conflict of interest occurs when ones private interest interferes or appears to interfere in any way
with the interest of the organization. According to Sliglitz, it can be argued that there
is no conflict of interest because, based on Adam Smith's view, the individuals, when pursuing
their own self-interest are actually pursuing the general interest of society (Sliglitz, 2003, 2).
Some examples of conflicts of interest are:

- diverting from the organization for personal benefit, a business opportunity,


- using the organization's assets for personal benefit,
- accepting any valuable thing from the organization's customers or suppliers, and
- having a financial interest in an organization's competitor.

Insider Trading
Insider trading is an unethical behavior which occurs when a person who has access to
confidential information uses or shares the information for securities trading purposes or
any other purpose except the conduct of regular company business. The confidential
information of the company are not to be used for achieving personal gain neither are they to be
disseminated directly or indirectly, to friends, family members and other outsiders who may in
turn trade on or misuse the information.

Harassment is a derogatory comment or unwelcome sexual advances.


Why People Behave Unethically
Dedicated employees, who are usually honest, sometimes behave unethically because of
four rationalizations: that no one will ever find out, that the behavior is not really illegal, that it
is in the best interest of the organization, and that the organization will protect them.
Although the costs of unethical behavior are hard to measure, they can add, according to
research, more than 20% to the cost of doing business. The costs will include low wages,
unemployment, and poverty. If top management wants to improve organizational performance,
they must stand firm that ethical methods are the only ways business should be done.

Causes of Unethical Behaviors


The study that was commissioned by American Management Association (AMA) and
which was conducted by the Human Resource Institute (HRI) using 1121 managers and
Human Resource experts as participants, revealed that the leading cause of unethical corporate
behavior is "pressure to meet unrealistic business objectives and deadlines." The study also
showed that the second leading factor that causes unethical behavior is the desire to further one's
career while the third leading factor is the desire to protect one's livelihood.

Job pressure, according to the study, causes employees to engage in unethical behaviors that
include cutting corners on quality control, covering up incidents and lying to customers.
Ignorance is another major cause of unethical behaviors. The study of (AMA) and
(HRI), (MacDo, 2006, 1), revealed that the ignorance that the acts are unethical and not
knowing the seriousness of the consequences when caught, are causes of unethical behaviors.

Competition for scarce resources, power or position can cause individuals to engage in
unethical behaviors. Hosmer emphasized that an attempt to improve their corporate competitive
positions made managers to take immoral actions (Hosmer, 1987, 439) . Bazerman and Banaji
felt that the cause of the unethical behaviors in organizations is the presence of a "few
bad apples" among organizational actors (Bazerman & Banaji , 2004, 111). The primary
cause of unethical behaviors can be traced to lack of maintaining the type of consistent leadership
that is necessary for running an ethical organization. This exposes the employees to opportunities
that make them engage in unethical behaviors.

Recommendations
The National Defense University proposed three ethical responses to unethical behaviors in their
"Strategic Leadership and Decision Making:" exit, voice and loyalty. With respect to "exit" it is
recommended that if one can not live with the behavior, or the behavior does not meet
one's ethical standards, one should leave. The second response, "voice," is to express discomfort
with and opposition to the unethical behavior. The third response, "loyalty," supports the
idea of remaining in the organization and trying to change it instead of leaving (National
Defense University, 1986, 8).

In order to restore and maintain a culture that upholds honest and ethical behaviors, the
organizational leaders must verbally promote ethical environment and relentlessly "walk
the talk," by making ethical behavior part of the organization's agenda. They need to
establish codes of business conduct to guide employees' behaviors. There should be the
establishment of annual business ethics training for the employees and a good whistle blowing
mechanism. Since job pressure was identified as major cause of unethical behavior, in order to
reduce the pressure, communications and commitment by top management are
recommended.

Conclusion
Today, there is a tremendous loss of confidence in corporate conduct and there is an urgent need
to work towards restoring it. Although ethics education seem to produce limited evidence of
changing behaviors, the commitment of management to monitor annual ethics education for all
employees will produce the desired favorable results. There should be clear
communication to the employees of what are honorable and expected behaviors in the
organization. They must maintain and stand firm on a clear cut policy that ethical
methods are the only way of doing business.
ARTICLE 5

The Only Solution to the Decline in Business Ethics:


Ethical Managers

August, 2007

By William P. Cordeiro

Definition of Business Ethics


Ethics is a value system by which individuals evaluate and judge the behaviors of themselves and
others. Behavior is evaluated against some previously established set of standards. The
traditional sources of ethical standards are religious, philosophical or cultural/societal value
systems. Hurley (1972) describes ethics as "a process by which individuals, social groups, and
societies evaluate their actions from a perspective of moral principles and values. This evaluation
may be on the basis of traditional convictions, of ideals sought, of goals desired, of moral laws to
be obeyed, of an improved quality of relations among humans and with the environment. When
we speak of 'ethics' and ethical reflection, we mean the activity of applying these various
yardsticks to the actions of persons and groups."

Ethics for business managers involves a series of behaviors that adhere to the values held by the
individual manager, the manager's supervisors and subordinates, the general society and, most
importantly, the managers' customers/clients (Bartlett, 1994). Steiner (2000) describes four levels
of business ethics on which the manager is evaluated:
1. The business system, with judgements made concerning the total effect of (capitalist)
business on society;
2. The industry, with separate industries having varying ethical standards: e.g., a pharmaceutical
firm vs. a movie studio;
3. The company, with individual firms having a wide variety of behavior patterns: e.g., Ben and
Jerry's vs. Dryers ice cream companies;
4. The individual manager, with each person responsible for their own behavior. Regardless of
their source, ethical standards and expectations exist for all firms and managers.

Managers and companies are expected to act in an ethical manner (Gilmore, 1986). A major
difficulty for managers, assuming that they choose to act ethically, is determining current or
expected ethical standards. This can be especially difficult for multinational managers facing a
variety of ethical expectations from diverse foreign cultures. Often, ethical standards are not
explicitly expressed, yet managers are still held accountable to the "assumed or understood"
standards.

The complexity of modern society and business increases the difficulty of determining the ethical
context of managers' actions. There is little problem identifying certain actions as unethical:
embezzling a trust fund; using an employer's assets for a personal business; practicing overt
racial discrimination. However, other business actions may be more difficult to characterize in
terms of ethics: Is denying a woman, in her child-bearing years, the right to work in a plant
containing toxic chemicals an unethical act of sex discrimination? Or, would allowing her to
work there be an unethical act of ignoring her industrial-related health? Recent Supreme Court
rulings do not answer this ethical question; they merely set legal precedents for litigation.
Clearly identified illegal actions can be viewed as ethical. American history has many examples:
the "Underground Railroad" helping escaping slaves violated many state laws; the nonviolent
civil rights and anti-war demonstrations of the 1960s violated many state laws; the publishing of
the Pentagon Papers violated several USA national security regulations. In business, paying
"sales commissions" to an official of a foreign customer nation violates the US Foreign Corrupt
Practices Act, but could be viewed by American workers as the ethical act of facilitating sales to
protect their jobs. Perhaps, not paying the commission could be viewed as a manager's ethical
failure - neglecting their duty to their worker stakeholders. Drucker (1974) quotes Hippocrates
when presenting the minimal standard of ethical behavior for all managers in all business
circumstances: Primum Non Nocere - "Above all, not knowingly do harm." Adding to such
general statements, many authors have developed lists of acceptable and unacceptable behaviors
for managers (Dalton, 1982). Goodpaster (1983) presents a list for managers that he calls "moral
common sense: avoid harming others, respect the rights of others, do not lie or cheat, keep
promises and contracts, obey the law, prevent harm to others, help those in need, be fair, and
reinforce these imperatives in others."

Declining Business Ethics


Even without a single agreed-upon definition of ethics, observations can be made concerning
business' adherence to generally accepted ethical principles. Unfortunately, there are many
examples of violations of current ethical standards by USA businesses: the substitution of
adulterated concentrates in Beech-Nut baby juices (Anonymous, 1989); the withholding of
information concerning the potential lethal nature of the Dalkon Shield intrauterine device
(Mintz, 1985); the felony murder conviction of managers of Film Recovery Systems of Chicago
when they exposed their workers to cyanide poison and deliberately covered up warning label
highlighting the danger (Anonymous, 1987). Other examples of ethical violations include the
behavior of the convicted bond broker Michael Milken (Rowe, 1990); the misuses of the banking
system (check kiting) by E.F. Hutton (Moskowitz, 1985); the massive Saving and Loan scandal;
the forging of customer signatures by Salomon Brothers in a scheme to dominate one day's
purchase of US Treasury notes (Galen, 1991); Sears auto repair shops charging customers for
new batteries, but installing used products; the continual marketing of deadly tobacco products to
children; securities analysts' clear conflicts-of-interest in promoting stocks that the analysts
personally own or that their firms represent in investment banking transactions (Morgenson
2001; Tully, 2001); and, Mitsubishi Motors covering up defects affecting thousands of cars
(Anonymous, 2001). Of course, there are many examples of ethical failures not involving
business organizations: the Salt Lake City Olympic Organizing Committee bribing members of
the International Olympic Selection Committee; President Clinton's questionable practices and
statements; the admission of lying and fabrications in his classroom by Pulitzer Prize winning
historian Joseph J. Ellis (Gorn, 2001).

A variety of research indicates that the American public perceives business ethics are in decline.
Clymber (1985) found that 55% of the American public thought that corporate executives were
dishonest. Jackson (1987) found that 49% of Americans thought that "white collar" crime is
common in business. Sandroff (1990) reported survey results in which over 50% of the
respondents believed that business ethics declined in the 1980-1990 decade. Michael Josephson
studies social, business and political ethics. He writes that all persons in all fields have the
potential for moral or immoral behavior (Wood, 1990). Josephson is very concerned with the
decline of ethical behavior in younger Americans. In one article, he identifies the "I-deserve-its"
or "IDIs" and notes that this group of young people demonstrate a "willingness to abandon
traditional ethical restraints in the pursuit of success, comfort or personal goals" (Josephson,
1990). To further explore these attitudes, structured interviews were conducted with fourteen
managers in a variety of organizations. The interviews were conducted between November 2000
and April 2001. The interviewees were senior managers in their organizations: Four work in a
very large county government that engages many business contractors on a regular basis. Most
contracting involves elaborate Request-for-Proposals (RFP) and "objective" bidding processes.
Three managers work for a very large state government that also uses many contractors. Four
managers work for large US-based corporations. The final three managers own and operate small
private businesses. All fourteen managers have been employed in their organization for over 10
years.

First, all managers stated that - in general - business ethics have been "getting worse" in the last
few years. Several linked the decline in business ethics to a decline in societal ethics. Most
mentioned "President Clinton's ethical problems" as an example of declining societal ethics.
Several also discussed the ongoing tobacco litigation and continual industrial pollution as
examples of unethical corporate behavior.

Second, each manager described a personal experience in the past few years with an unethical
action by a customer, contractor, superior or peer.

Third, all managers noted that they hear continual complaints from the public and their customers
about unethical business behavior.

Fourth, all managers offered a variety of suggestions to retard the decline in ethics, including:
teach ethics in schools, develop Codes of Ethical Conduct, establish better monitoring and
reporting mechanisms, and hire "more honest people." Fifth, almost all managers were
pessimistic concerning business ethics, indicating that they thought the decline would continue.

Effects of Declining Business Ethics


Assuming a decline in business ethics or, at a minimum, a perception of a decline, what is the
significance? Does it really matter if more business people are committing unethical acts (or at
least getting caught more often)? Yes! It is significant for two reasons:
First, the decline in ethics is bad-for-business and reflects an erosion of the principles needed for
an ordered and functional modern technical society. The USA economic system is built on a
series of values: trust, honesty, keeping commitments (contracts), respect for others' property,
cooperation. Of course, there have always been examples of gross abuses, exploitation and
misconduct. But as Bowie (1997) notes, a minimum "market place morality" is a requirement for
business success. An efficient market needs standards of behavior based on some level of truth
and trust. An article by the former Chairman of IBM, John Akers (1989), closely links American
competitiveness and ethics: "No society will compete very successfully with people stabbing
each other in the back; with people trying to steal from each other…; it is a recipe for a nation to
become wasteful, inefficient and non-competitive…; the greater the measure of mutual trust and
confidence in the ethics of society, the greater its economic strength." Silk (1989a) agrees that
unethical behavior "will create a world of dog-eat-dog in which everyone ultimately
loses…ethical principles constitute one of the strongest forces for keeping a society healthy and
growing."

Second, the decline of business ethics is bad-business. Its stakeholders are important evaluators
of business' ethical behavior: the individual managers, peer managers, workers, general society,
government and - most importantly - the customers/clients. In this arena, perception is extremely
important (Morgan, 1993). Based on their perceptions, the stakeholders judge business as either
ethical or unethical. Modern media, especially the proliferation of "news" sources, relentlessly
shape the public's perceptions of ethical behavior. Multiple TV channels devoted to business
(e.g., Bloomberg, CNBC, FNN and MSNBC) run 24 hours per day. The Internet provides a
constant source for general news and business news. Internet "chat rooms" facilitate a wide
exchange of data, much of it false, about all aspects of business behavior and alleged
misbehavior (Anonymous, 2001). While these perceptions and subjective standards may make
managers uncomfortable, they are a fact-of-life for all organizations today (Prystay, 2001). For
example, the makers of Sudafed were not judged as "responsive and concerned about the public's
welfare" as the maker of Tylenol were, when both responded to the use of their products by a
random murderer (Horovitz, 1991). Another example: if the public perceives a firm as a polluter,
even though the firm regularly invests in pollution control equipment, then the firm must adjust
its actions or the portrayal of its actions accordingly (Hosmer, 1991). Although all organizations,
including business, must satisfy its customer/clients' needs, it can be dangerous to base ethical
standards solely on the latest opinion poll. At some level, ethics cannot be totally relative - even
for business organizations. There must be a set of guiding ethical principles to "prevent a person
from pulling the lever at Auschwitz" because the act was deemed ethical by a Nazi-dominated
society (Goddard, 1998). Recently, firms abandoned their fiduciary standards by permitting
almost anyone to be "day traders" - a practice that led to financial ruin for many clients. The
1990s bull market, especially the late 1990s "dot.com mania", created an environment in which
clients demanded ever-higher investment returns. These unrealistic client demands in turn led
firms to ignore well-known historical investment standards. By following their clients' wishes,
the firms violated their fiduciary obligation to reasonably protect their clients' financial assets.
Retarding the Decline of Business Ethics
As noted earlier, the managers I interviewed made four suggestions on how to retard the decline
in ethics: 1) teach ethics in schools, 2) develop Codes of Ethical Conduct, 3) establish better
monitoring and reporting mechanisms, and, 4) hire "more honest people." Many authors have
offered similar recommendations.

Teach ethics in school: There is little debate over the need to teach values and ethical principles
to young persons. Thompson (1989) describes a program in North Kansas City in which high
school students are taught basic values "that form the basis for decision-making…honesty,
generosity, helpfulness, self-reliance and kindness." Thorn (1988) discusses research findings on
the intellectual development of children, noting that "ethics have to be taught." There is
disagreement over the usefulness of trying to teach ethics to university students, especially to
graduate students in business schools. An obvious proponent of teaching ethics to graduate
business students is John S. Shad, the former SEC Chairman, who donated $30 million to the
Harvard Business School to foster the exploration of ethical issues (Byrne, 1987). While agreeing
that teaching ethics may be useful, Akers (1989) cautions not to expect dramatic changes in
students' behavior.

Bunke (1988) also questions the efficacy of teaching ethics in business schools. He recommends
that society emphasize the inculcation of personal values through the family, pre-collegiate
schools and religious institutions: "Maybe teach one small course…in the MBA curriculum to
remind out technically trained and frighteningly ambitious students that our business system will
endure only so long as it is solidly rooted in meaningful idealism."

Develop Codes of Ethical Conduct: The interviewees proposed written Codes of Ethical Conduct
for business organizations. Several emphasized the need for written codes in large organizations
as a method of disseminating the ethical standards to a dispersed workforce. Since an
organization may have thousands or hundreds of thousands of workers, all need a written
statement of the firm's ethical standards. These written codes promote and mold approved
behaviors within the organization.

In fact, most large American companies have a written Code of Ethical Conduct, often widely
distributed and publicized (Fisher et al, 2001). The Ethical Resource Center in Washington, DC
estimated that 92% of the 2,000 largest American firms have a written Code of Ethics and about
33% have programs to educate their employees concerning the firms' view of ethical behavior
(Anonymous, 1990). Unfortunately, having a written Code of Ethical Conduct may not mean that
firms are acting ethically. A survey of 350 firms determined that those with a written Code of
Ethical Conduct were "more often charged with wrongdoing than those without such policies"
(Barrett, 1988). For example, despite having all employees sign a Code of Ethical Conduct, Hertz
publicly admitted to overcharging its customers $13 million during a two-year period. Some
authors have suggested that a written Code of Ethical Conduct provide employees with a
"psychological cover" for unethical behavior. The employees know the firm has a Code and,
therefore, their actions must be OK or ethical (Somers, 2001).

Establish better monitoring and control mechanisms: Several interviewees stated that
organizations needed more effective systems to monitor behaviors related to ethical decision-
making. Somers (2001) agrees that Codes are not enough. Firms must have processes in place to
report unethical behaviors. The existence of Codes of Ethical Conduct is helpful, but the
organization must make the practice of ethics an integral part of its daily activities. Most
important activities of organizations are monitored, reported on, and analyzed. The practice of
ethics should be treated like other important corporate activities (Fisher, 2001).

Hire more honest people: The interviewees stressed that the most important element of an
"ethical organization" is the individual. The key to ethical performance is hiring and promoting
ethical people. The most important "ethical people" in the organization are those at the top - the
leaders. In business, managers are usually considered equivalent to leaders, though some authors
reject a strict equivalency (Zaleznik, 1986). There are many examples of persons without
management titles who are effective leaders - based on their ability, assumed authority,
personality and accomplishments. The ball players, Babe Ruth, Johnny Unitas, Magic Johnson
are examples of team leaders who exerted powerful influence on their teams (or co-workers)
through charisma and ability, without being the official manager or coach (Hitt, 1989).
While leaders are important in performing most functions (strategic and tactical planning,
staffing, finance, marketing, etc.), they are essential in organizational adherence to ethical
principles (Bloskie, 1995). The difficulty in defining an organization's ethics often results in the
leader becoming the embodiment of the organization's ethical principles (Dukerich et al, 1990).
The person at the top is continually observed for ethical signals. William F. May, the former
CEO of American Can Company, said that "the CEO has a unique responsibility: He's the role
model. What he does, how he lives, and the principles under which he operates become those of
the rest of the corporation" (Anonymous, 1988).There are a variety of techniques and suggestions
to assist the leader in promoting ethical behavior. Goddard (1988) recommends several rocesses:
"Identify ethical attitudes critical to your specific operation, select employees with the desired
ethical attitudes, establish a work culture that reinforces the ethical attitudes and increases
employee participation in (ethical) decision making, and exhibit ethical leadership." Since
leaders are very closely observed by their subordinates, leaders cannot merely espouse ethics,
they must be ethical. Many studies have demonstrated that workers follow their managers: not
what managers say or publish, but what managers do (Schriesheim, 1980). Organizations adopt
and follow the ethics, style, and methods of their leader. Workers quickly identify
inconsistencies; and are even quicker to identify phonies or hypocrites. Duke de la
Rouchefoucauld once cynically observed that "Hypocrisy is the homage that vice pays to virtue"
(Silk, 1989b); and workers quickly spot hypocrisy. The leader's importance translates into close
scrutiny of their most subtle behavior. The leader's position "amplifies his/her most causal
judgement, jokes, and silences" (Andrews, 1989). Bird (1989) writes of the "moral muteness of
managers" who choose not to exercise their responsibility in relation to ethical issues. If top
managers, through their daily behavior and comments, indicate that ethics are personally
important to them, the workers will act accordingly (Marinko, 1987).

Conclusion
While a single definition of American business ethics does not exist, American society (and this
paper's interviewees) expects business to act ethically. This is especially true of large American
firms. Of the many ways to foster ethics within an organization, the most important is the ethical
leadership of managers (Groner, 1996). A major difficulty occurs when the manager/leader is not
ethical. Education, Codes of Ethical Conduct and monitoring are probably not complete
solutions. Dechant (1990) writes that it is not possible to train or educate leaders to be ethical if
they are not already ethical (before they join an organization). Ironically, "organization or
corporate" ethics are not a collective matter, but rather an individual responsibility (Nixon,
1993). The personal ethical standards of the manager/leader set the collective standards for the
organization (Butcher, 1997b). Ethics is not something that a manager "does"; it is something
that the manager "is". The late Thornton Bradshaw, former CEO of RCA and former President of
ARCO, recommended that leaders should "merge your own set of ethics and values into what
you do during the day. If you have to draw a curtain down when you go to work in the morning,
and spend eight hours doing something that you don't believe in, then you're in trouble"
(Goddard, 1998). If business ethics are in decline, the only solution is increased ethical
leadership from the top.
ARTICLE 6

Ethical practices linked to profitability


Friday, May 30, 2008
San Antonio Business Journal - by Paul A. Parks

How would you like to build your company's reputation, enhance your relationships with key
markets, reduce your risk, attract and keep better employees, be better prepared for crisis and
sustain long-term growth? It starts with a strong ethical culture. Yet fewer than one in 10
companies today has one in place, according to the most recent Ethics Resource Center's 2007
National Business Ethics Survey.

The research into ethical practices and profitability shows mixed results. While there are too
many variables to conclusively prove that ethical behavior leads to increased profits, the majority
of studies demonstrate a statistically relevant connection.

Poor ethics can be very costly. Federal legislation, such as the Sarbanes-Oxley Act and the
Federal Sentencing Guidelines have made it very clear that companies are responsible for
employee misconduct when the employee is acting in an official capacity regardless of whether
or not the company was aware of the misconduct or not.

Good ethics, on the other hand, can be quite beneficial. At the very least, an ethical culture
reduces the high-pressure, non-communicative, highly politicized work environments that can
exist. But at its best, ethical cultures lead to employee satisfaction, which fuels profitability.

Satisfied employees consistently out produce and outperform those employees who are less
satisfied in their work environments. In the most recent study, The Wharton School at the
University of Pennsylvania found that firms considered to be good places to work earn returns
that are more than double those in the overall market.

While many studies have documented the fact that a sense of fairness is critical to developing
consistent and long-term business relationships, one study took the idea a step further to show
that fairness in business dealings can maximize profitability.

Here's how it works: When a manufacturer treats a retailer fairly, the retailer reciprocates by
picking a retail price that rewards the manufacturer. The relationship flourishes. This is not a
new idea. "Tit for tat" is a common ethical algorithm.
And while it's not rocket science, it is definitely brain science. In a growing area of research
known as neuroeconomics, researchers have shown that when people sense they are being treated
unfairly, the same area of the brain that registers disgust lights up. However, the area of the brain
responsible for more higher order thinking lights up when reciprocity is perceived.

Yet, regardless of what we instinctively know to be true, our culture and society has taught us
otherwise. The survey says ethical misconduct is back at pre-Enron levels. We have moved from
enhancing profitability to putting all profitability at risk.

Today's companies, according to the Business Ethics Survey, are most at risk for employees
acting on conflicts of interest, lying to other employees or participating in abusive or
intimidating behavior. Not so high on the list, but still areas of high risk, are Internet abuse, lying
to stakeholders, discrimination, safety violations, improper hiring practices, sexual harassment,
stealing and providing low quality goods or services.

Ethics codes can make a difference. Still, it is not enough to have a one-dimensional policy
designed to comply with laws and regulations. Companies must embed ethics in and throughout
the corporate environment in order to have any significant effect. When that happens, that strong
ethical culture has been shown to reduce misconduct by almost as much as 75 percent.

Making it work
There are several key ingredients to making an ethics policy work in the real world. According to
the Ethics Resource Center, research has identified six basic elements:

 Written standards
 Training
 A way for employees to seek ethics-related advice
 An anonymous way for employees to report misconduct
 Clear consequences for violations
 Inclusion of ethical conduct as part of an employee's performance valuation

Each element contributes to the reduction of misconduct and, in fact, can increase bottom line
performance. For example, a recent study out of London's Institute of Business Ethics showed
that businesses that train staff to understand and implement ethics codes financially outperform
those that do not add in the training element.

Yet, even though there is enough evidence to support the financial gains from ethical behavior,
this cannot be the focus for a company's movement towards a better, more ethical way of
conducting business. Ethics cannot simply be a function of risk management. When ethics
orientations are primarily compliance-based, studies show that employees have relatively little
buy-in and are less likely to report misconduct or seek help in solving ethical dilemmas.
The most effective programs are values-based. They define an organization's core beliefs and
values, encourage those values to become central to the organization's culture, and empower
employees to commit to those ethical objectives.

So take some time over the next few weeks and months to begin to define your corporate values
and ethical expectations. How do you want them to affect your company culture and what
outcomes do you desire from implementing an ethics program? At the very least, begin the
discussion.
ARTICLE 7

Trust, ethical behavior at core of good practices


Friday, June 30, 2006
Denver Business Journal - by Scott Harris

It used to be that employees worried their bosses might be incompetent. Now it seems they're
more concerned their bosses might be dishonest.

It's no wonder. Witness the likes of Martha Stewart and Kenneth Lay -- both of whom were
found to be guilty of betraying trust.

The International Coal Group was accused of betraying trust during the West Virginia Sago
Mine tragedy, when it waited three hours to inform families that their loved ones were deceased
-- though the company knew they were dead within 20 minutes.

So what can be done to restore trust?

Ethical behavior is defined as a series of response patterns that others acknowledge as being
honorable. We must understand what honorable behaviors are before we can figure out which
ones aren't.

If only it were that simple. It's hard when we're faced with serious ethical dilemmas in our
workplaces.

Think about the companies with the best reputations. What do they have in common?

Well, they understand that to have a good reputation, they must balance competitive zeal with a
passion for trust.

Businesses, particularly unethical ones, tend to shift blame. When bad decisions are made, they
tend to blame someone else -- the government, the community, the competition -- for their woes.

Often, that's when public relations professionals are called in to make the silver lining magically
appear. But it's nearly impossible when organizations have engaged in one or more of the
following dishonorable behaviors:

 Exercising limited or no control over employees.


 Encouraging supervisors to overlook bad behavior.
 Permitting a "do whatever it takes" mentality to permeate throughout.
 Giving lip service to being an ethically driven, highly principled organization.
 Structuring incentives that force safety, public health or product integrity to be
compromised.
 Ignoring signs of rogue behavior.

If there's even a remote possibility that a client's action could be perceived as unethical or not
trustworthy, the PR pro should convince them to forgo it.

Ethical, honorable businesses and organizations of all types begin with senior management
setting a fundamental communication and PR policy based on five key principles:

 Openness -- The organization is committed to openness and accessibility. The right


people are available and willing to respond or speak out when something needs to be
discussed.
 Truthfulness -- To completely resolve a problem, the organization will need to be honest
and understand the points of reference of others affected by its actions.
 Responsiveness -- We must understand that any constituent concern is legitimate and
must be addressed. Too often, we simply don't respect the person in rags, the angry
neighbor, the passionate demonstrator or someone who -- while holding their baby -- cries
and complains about what some company did to them. And, we don't respect the questions
these people ask.

If we're a truly responsive organization, those are the questions we want to hear. Our answers to
those questions will settle things down and help us move forward.

 No secrets -- There are few secrets anymore. That's because the Internet, blogs,
aggressive 24-hour reporting, word-of-mouth -- you name it -- have erased the chances of
keeping things secret for long. Our behavior, attitudes, plans, even our strategic discussions
must be unchallengeable, unassailable and positive.

If you don't want to see it in the media, don't say or do it.

 Engagement -- A crucial element in restitution or mitigation, or simply increasing


understanding, is interacting with those who have different points of view. Increasingly, the
credibility of our response to important situations is judged by our willingness to sit down
and talk, negotiate, mediate or mitigate.

This is clearly the most difficult activity for management to undertake because it's a "soft"
activity in terms of measurability, and one for which business people, especially, have no
practical training.

At its best, PR builds trust and fosters mutual respect among distinct audiences. Effective PR
pros capture an understanding of a situation and its consequences, and then direct management to
communicate the pertinent specifics to key audiences. Anyone lying or distorting information to
manipulate a situation is unethical.
It's about working with integrity. A fundamental part of achieving good PR and a good
reputation is conducting oneself or one's business in ways that contribute to some greater good
through ethical behavior and an enlightened self-interest.

Be aware that the strong trust and positive reputation you build during good times can carry you
through the worst of times. And that can affect the bottom line.
ARTICLE 8

Ethical imperatives must be in business plan


Friday, April 28, 2006
San Antonio Business Journal - by Glenda Vosburgh

Our fast-changing world and ever-expanding economy creates all kinds of potential land mines
for companies trying to tread an ethical pathway, and the challenges are expected to grow in the
next 10 years.

Changes in technology, expansion of U.S. businesses into every corner of the globe and
pressures to remain profitable in a post-Enron and Worldcom business environment require
proactive leadership, planning and commitment to business ethics by every individual in the
company. No small task.

Yet, according to a survey commissioned by the American Management Association (AMA)


and conducted by the Human Resource Institute, creating and maintaining ethical practices in a
business is high on the list of desired initiatives of many company honchos.

According to the survey, titled "The Ethical Enterprise," the No. 1 reason for maintaining an
ethical company culture today is to protect the company's brand and reputation. Rounding out the
top five reasons are:

 Because it's the right thing to do;


 To ensure customer trust and loyalty;
 Investor confidence; and
 Public acceptance and recognition.

Outside influences
The top business driver of company ethics today, according to responses from survey
participants, is corporate scandals, followed in importance by marketplace competition, demands
by investors, pressure from customers and globalization.

But business leaders shouldn't get too comfortable with that list because, in 10 years, the order of
importance is expected to change, with the No. 1 driver being globalization, followed in order by
marketplace competition, pressure from customers, corporate scandals and demand by investors.
Globalization, survey conductors said, brings a number of ethical challenges, especially in
developing nations where issues related to forced labor, child labor and working conditions are
major concerns.

Fast-changing technologies are growing ever more powerful and pervasive and are expected to
present any number of ethical issues for companies in the next decade. Survey participants were
also asked what external factors would affect business ethics. Laws and regulations were viewed
as the most important external driver today and in the future. But environmental issues jump
from ninth on the list to the No. 2 slot when participants were asked to look ahead 10 years.

According to the survey conductors, that could signal increased interest in "green" business
practices over the coming decade.

Root causes
"Laws and regulations are, and will remain, the most influential external drivers of corporate
ethics, but legislation is no substitute for the presence of leaders who support and model ethical
behavior," says Edward T. Reilly, president and CEO of AMA. "Corporate leaders need to
communicate ethical values throughout the organization, but they must do more than talk the
talk."

The survey found that the single most important ethical leadership behavior is keeping promises,
followed by encouraging open communications, keeping employees informed, and supporting
employees who uphold ethical standards. "If an organization has leaders who simply don't walk
the talk when it comes to ethics," survey conductors point out, "there is little hope of maintaining
a strong ethical culture."

Which brings us to the No. 1 cause of unethical behavior in companies. According to the survey,
pressure from management or the board to meet unrealistic business objectives and deadlines is
most likely to cause unethical corporate behavior. Other factors are the desire to carry out the
boss's orders, to further one's career and to protect one's livelihood.

How can companies prepare for the future while encouraging ethical practices today?

According to the survey, companies should establish policies and processes aimed at ensuring an
ethical culture. Those can include leadership support and modeling of ethical behavior,
consistent communication from all leaders, integrating ethics into goals, processes and strategies,
and making ethics part of performance management systems and the recruitment and employee-
selection process.

A code of conduct should be a top priority with all business, the survey said. And companies
should also consider other programs like ethics training for all employees or corporate social
responsibility programs. Employees should have a code to establish the company's ethics
foundation, training to help them understand it and programs in place that allow them to inquire
about and report ethical violations.
ARTICLE 9

Ethical behavior fosters long-term success


Friday, February 18, 2005
Jacksonville Business Journal - by Paul Ellis

During a recent speaking engagement, a college student asked me whether the Sarbanes-Oxley
Act of 2002 had improved corporate ethical behavior. My response was a surprising "No" until I
offered the audience a more detailed explanation.

The act definitely added a layer of discipline to how companies must approach ethics. That
discipline, for the most part, is good for business. But if ethical direction is not driven from the
top of an organization, no amount of legislation will change the way individuals or companies
approach their business affairs. As I see it, the issue is not if companies or individuals will, or
won't, have to deal with unethical behavior at some point, but how they respond to it.

The way business leaders and employees react to these situations depends a great deal on their
surrounding environment as well as their own beliefs. These decisions generally are driven by
two primary factors:

 A corporate platform that encourages ethical decisions and has a core set of values.
 An individual's own convictions and personal approach to the way business should be
done.

The big question, then, becomes this: Can businesses become truly successful while adhering to
a strong ethical code? In my opinion, embracing deep-seated principles is part of the definition of
a successful business. And while achieving excellent financial results is another part of that
definition, the ultimate goal is building a robust, sustainable business platform upon solid
relationships. You absolutely can't do that without steadfast ethics.

Successful results are the product of actions and policies. In truth, there are many elements that
will affect a company's bottom line. Ethical behavior is just one of them.

Certainly, short-term success can be achieved through unethical practices, as was evidenced
recently by Enron and WorldCom. However, we also are very well aware of the embarrassing
and disastrous financial fallout that resulted in those cases.
Over the long term, colleagues, clients and vendors want to deal with ethical companies and
people. No one wants an ugly surprise tied to an agreement. Everyone wants to be treated fairly.
A good code of ethics balances a company's interests along with those of its clients, its
community, and its environment. It's just good business sense -- and that's what promotes
sustainable success.

Finally, we have to recognize that we are essentially dealing with human behavior, which is
flawed. People do make mistakes. As leaders, we must mentor them and set excellent examples
of how to deal with unethical situations. If individuals can't be coached, then they should be
removed from an organization. Because none of us is perfect, it's essential that corporate culture
promotes doing what's right and provides the support necessary to stay the course.

Sarbanes-Oxley may have codified how companies must approach goals today, but didn't
introduce them to those basic concepts. Respect, integrity, service and excellence have been at
the core of many successful business cultures long before the enactment of this legislation.

That's why, when someone asks whether businesses can thrive if they must follow a strong
ethical code, I feel confident in replying "Yes."

In fact, I believe it's the only way to do business.


ARTICLE 10

Companies take ethical issues off the back burner


Friday, June 13, 2003
Houston Business Journal - by Thora Qaddumi

Company managers, often occupied with trying to "slay the last dragon," are finding it pays to
take some easily neglected concepts off the back burner.

"Ethics," "diversity," and "team-building" should be main ingredients in the strategic planning
recipe, rather than ideas taken out of context, left simmering and served as an afterthought, says
business adviser and speaker Hank Moore.

Moore, president of Management Resource Institute (www.selec.net/businesstree), is author of


numerous books, including "The Business Tree," the 10-tape audio cassette series, "$50 Million
Business Makeover" and, his most recently published volume, "The High Cost of Doing
Nothing." A consultant who leaders of many companies turn to for help in achieving "big
picture" plans, he has trademarked the term "corporate strategist" as defining his role.

Moore's next book -- with the intriguing title, "The Future Has Moved ... And Left No
Forwarding Address" -- is on corporate responsibility. It includes his "Seven Levels of
Standards, Ethics", an application of his trademarked "Business Tree" approach to growing,
strengthening and evolving businesses.

Moore defines "ethics" as "the science of morals, rightness and obligations in human affairs."

All levels of standards and ethics are part of the tree, starting with Level 1, "base-level ethics,"
represented as being high in the branches. This is knowing right from wrong and "trying to
pursue a good life and aspiring to something better."

Level 2, lower in the branches, are prevailing philosophies and behaviors ("society's lowest
denominators"); Level 3, "lessons learned from the school of hard knocks," and Level 4, efforts
to learn more and go further ("launching a quest").

Level 5 is "standards" -- including establishing and respecting boundaries. The trunk of the tree,
which supports the whole plant, is Level 6, "values and vision," where it is recognized that
"success comes from charting a course, encompassing value systems and methodically reaching
goals."
Level 7, the roots of the tree, becomes the "code of ethics," which includes "fundamental canons,
rules of practice, professional obligations, accountability-measurability, professional
development, integrity, objectivity and independence."

"Company managers think that by putting more money behind technology or marketing,
everything will be fine. They call in consultants," Moore notes.

What they really need, he says, is a plan that provides a true vision of the company that allows
long-term growth. And part of the plan should be a carefully formulated, distributed and
continuously reviewed ethics statement and program.

"Companies that fail to address ethical issues of the day are endangered species," he says. "You
don't want to be too preachy. You just have to inculcate ethics in everything you do. Eighty-five
percent of the time, if you plan for a crisis, you avert it. You determine what could be the biggest
ethical dilemmas and you take proactive steps to avert them."

Every organization will differ in how it implements corporate responsibility and ethics programs.
The main point, however, is that business ethics encompasses much more than accounting fraud
and the publicly stated values of stocks.

"The program seeks to create conditions that support the right actions," Moore says. "It
communicates the values and vision of the organization."

"A formal and well-documented corporate ethics program, developed as part of the planning
process, will prevent ethical misconduct, monetary losses and losses to reputation," he says. "If
communicated well, it may breed customer trust."

Moore recommends that companies establish organizational roles to manage ethics and send
copies of their ethics statement to customers, suppliers, regulators and other stakeholders,
demonstrating that the company is attempting to become a model.

"It becomes a good marketing mailing," he says, "and formal attention to ethics in the workplace
is the right thing to do."
ARTICLE 11

Ethical companies help employees avoid the near occasion of


sin
Friday, June 13, 2003
Houston Business Journal - by Randal Breaux

Ethical companies manage on-the-job temptation to help employees avoid the near occasion of
sin.

Creating an organization that is committed to high ethical standards is just plain hard. After all,
an organization is only as ethical as its weakest link -- the employee most likely to cave into
temptation, and temptation is often very strong.

Selection is one common solution: companies strive to hire only employees who have high
ethical standards. The problem with this approach is that ethics is something that is notoriously
difficult to test for, since most can figure out what answers an interviewer is looking for.
Furthermore, a person's ethical standards sometimes slip with changing conditions in his
personal life. An employee that develops a gambling problem after he has been hired may not
make the same decisions as he did when he was interviewed.

No selection process can overcome the simple fact that employees are human, and when humans
have powerful incentives -- both financial and non-financial -- to cheat, some inevitably will.
Organizations that are truly committed to maintaining high ethical standards must do more than
tell employees to just say no despite often-powerful temptations; they must take responsibility
for managing this temptation.

Control systems
One straightforward approach is simply to keep employees out of situations that could be
tempting, what the Catholic Church calls avoiding the near occasion of sin. This approach is
most common in accounting control systems. For example, the accounts payable clerk who
deposits checks is not the same person in most companies who reconciles bank statements. In
this way, the clerk cannot run off to Tahiti with a pile of checks and get away with it.

Employees might very well see these control systems as an indication that the company they
work for does not trust them, but most understand that such systems are necessary to avoid
creating undue temptation.
Of course, having accounting control systems is in a company's narrowly defined best interest. It
is nice that they lead to more ethical behavior, but that is not the driving force behind them.
Employees stealing checks cost money, so it is not surprising then that control systems are
common -- they save money.

Walking away
What are less common are practices that companies use to avoid temptation that cost them
money, but they do exist. Chuck Heaton, vice president of human resources of ITS Caleb Brett,
an oil and chemical inspection and testing company, gives one example.

"Our job is to make sure our customers enjoy a fair transaction by measuring the quantity and
quality of the products they exchange," he says. "Through experience we have found that some
clients are simply not interested in a fair exchange. We just can't do business with people like
that."

Ethical behavior is in part a function of the people with whom a business person associates.
Some customers cannot be trusted, and if so, truly ethical companies will walk away from the
business -- despite potential profits.

Similar moral dilemmas are common. Lowest-priced vendors sometimes exploit third-world
workers, skirt environmental regulations, or refuse to back-up the safety of their products. There
are areas of the world -- indeed, areas of this country -- in which doing business requires handing
out bribes. Organizations that are truly committed to maintaining ethical standards need to think
hard about whether doing business with these kinds of people is a viable alternative.

Walking the Line


Unfortunately, avoiding temptation completely is not always an option in some cases, and
employees are forced to deal with situations in which they must negotiate murky ethical issues.
In these cases, companies can still minimize the affects of undue temptation using the same
tactics they use in accounting systems.

 Limiting exposure. Temptation is like radiation: the longer a person is exposed, the
greater the risk. Smart managers avoid keeping any one person exposed to situations of
undue temptation for extended periods of time, rotating in other employees whose moral
fiber has not had a chance to be whittled away.
 Structuring jobs so that at least two employees would have to cooperate to break the
rules. Achieving duplicity with another employee is a lot riskier than doing something
alone because the other person may decide to expose his colleague. Smart companies
purposely split up job responsibilities for positions that are at risk to create this dynamic.
 Achieving high corporate standards through leadership. Company leaders need to make
ethical behavior more than a mantra; they have to demonstrate their commitment with
action. That commitment extends beyond the actions they perform themselves; it includes
the actions they reward in others. If people get ahead in an organization by cheating the
system, more will cheat.
In the end, corporate behavior is just the sum total of the moral decisions made by its individual
employees.

Being a truly ethical company is more than publishing a just-say-no policy in the annual report; it
means doing everything the company can to ensure that their choices are the right ones by
helping to manage the temptations they face -- even when doing so may mean lower profits.

In this way they create a company culture of doing the right thing, so that employees make the
right choices regardless of whether the boss is around or not.
ARTICLE 12

Boardrooms facing ethical issues in executive compensation


plans
Friday, June 13, 2003
Houston Business Journal - by Brent Longnecker and Chris Crawford

At proxy season, investors and the media direct their outrage at executive compensation. Add the
fuel of four years of a down economy and unprecedented corporate corruption exposed, and
there is no shortage of opinion on how or what executives should be paid.

Some key ethical issues relate to executive pay. Two areas that are highly charged inside the
boardroom are underwater stock options and hiring two consultants for the sake of independence.

Underwater stock options


In a bear market such as experienced as of late, the performance of a stock can drop to the point
that the exercise price of an employee stock option is greater than the fair market value of the
company's stock. This may even happen despite good performance of the company or employee.

As a result, the company loses the intended motivation factor in granting these options and
shareholders are diluted with stock not working in their behalf.

This is the situation faced by a majority of companies today. In fact, recent data indicates over 90
percent of option holders have at least one grant of stock options that are underwater. Board
members are struggling to retain key executives, because a significant portion of the executive's
pay may never be realized -- while the competitor across the street has attractive offers with low-
priced stock options.

While some boards have done nothing to reinstate lost value to the executives because of
shareholder sentiment, others have taken a stronger stand. Some of the reactive solutions to
underwater stock options that companies have utilized include:

 Cancel outstanding options and delay new awards for six months and one day.
 Option cancellation in exchange for restricted stock.
 Acceleration of new stock option grants.
 Acceleration of new restricted stock awards.
 Cash out existing underwater option (typically 50 cents to $1 per share).
 Acceleration of vesting schedules.
To help avoid the situation of underwater options, proactive companies should consider several
strategic initiatives:

 Diversify the long-term incentive portfolio with the use of stock options, restricted stock
and performance units.
 Award stock options and restricted stock on a more frequent basis (not more stock) to
dollar cost average.
 Shorten vesting schedules.
 Shorten terms of awards.

While underwater stock options continue to be a growing problem, boards have the ethical
dilemma of how to resolve attraction, retention and motivation of key executives while
shareholders, including board members, do not typically have the luxury of repricing
alternatives.

Ultimately, boards must weigh the outcry of the uneducated versus keeping top talent to drive the
ship through the four-year storm. Even though the decision is not easy, finding workable
solutions to attract, retain and motivate the very best talent will ultimately maximize shareholder
value.

Two consultants
Independence has now become an even hotter word as compensation and corporate governance
remains under further scrutiny. Consultants hired by organizations to advise and assist with
executive compensation and other complex issues are brought in and are expected to be
independent, with no conflicts of interest, no bias, and not susceptible to coercion.

However, as is often the case, the consultants are typically hired by either the board of directors
or the management team and sometimes favor whichever side they were hired to represent. As a
result, in an effort to maintain the independent, objective approach consultants are hired to
provide, companies are beginning to consider engaging two consultants -- one to represent each
of the "opposing" sides -- board and executives.

This practice begs the question: Are two consultants better than one?

Even consultants, themselves, in an effort to increase their sales opportunities, might tell you that
it is best to hire two consultants. However, ramifications of such a scenario with two consultants
representing their respective clients must be considered.

In this situation, each side would have its own approach and solutions to serve its own best
interests. A series of negotiations would then follow to allow the sides to reach an agreement.
Such a scenario is almost guaranteed to cause undue friction, drag on indefinitely and cost more
than it should -- with only the consultants coming out as winners.

Perhaps this would not be best after all. Perhaps there is a better answer -- one consultant with
ethics. This six-letter word can make a world of difference -- as anyone can see after reading
recent business headlines. One consultant with ethical standards can eliminate the need for hiring
two consultants.

For consultants, maintaining ethical practices will avoid the expected position of swaying
recommendations to any one side. One consultant operating with honest and fair objectives will
be able to provide solutions that are right down the line and truly independent. This consultant
should then be a good speaker in order to easily convey the right answers to both sides.

To ensure ethical compliance, consultants should sign an affidavit attesting to their independence
and guaranteeing they were not coerced or swayed by any and all parties concerned. In the end,
an ethical consultant can save the company both dollars and headaches.

There is no question, executive compensation is an issue that will continue to receive massive
attention from employees, shareholders, legislators and the media.

No matter what side of the equation a stakeholder falls on, the refiner's fire felt by corporate
America today is sure to forever impact the ethics of executive compensation.
ARTICLE 13

Business ethics more than fashionable behavior


Friday, November 29, 2002
Houston Business Journal - by Jim Eskin

Some people are saying Enron has put business ethics back in vogue. It certainly has focused
attention on the subject, but that mindset is likely part of the problem.

Business ethics isn't something that should be allowed to slip in and out of style. The Enron
experience has also shined the spotlight on the role of CEOs and senior management as a lot of
the responsibility for the ethical breakdown can be traced to plush corner offices. But this also
shirks the real issue.

While it is essential that CEOs and senior management lead by example, people at all levels of
an organization, not just at the top, confront dilemmas all the time in the workplace. Their
collective behavior determines whether organizations sink or swim in the ethical pools.

Accountability must be shared. We all come face-to-face with decisions that test our character.
While they differ in form and scale, they are all ethical tests with real consequences. Common
temptations include:

• Copying software from the office computer for home use.

• Padding an expense report.

• Embellishing résumés.

• Calling in sick (when you're not).

Incidentally, using e-mail to spread gossip and rumors about co-workers has grown into one of
the most frequent breaches of ethics in today's high-tech environment.

Let's step back for a moment. What do we mean by business ethics? There's a tendency to make
it too philosophical and abstract. It doesn't have to be that way. More often than not, it can be
boiled down to a simple extension of the Golden Rule.

Ethical reasoning centers on the ability to see and understand different perspectives and
viewpoints, and the capacity to put yourself in someone else's shoes.
It's not just knowing what's in it for you. It's weighing the impact on other people.

So what happened at Enron, a leading corporation that had an impressive corporate social
responsibility record on volunteerism, the environment and philanthropy?

Enron was repeatedly named one of the best companies to work for. It even had a nicely worded
code of ethics. What Enron didn't have was the people with the heart and guts to back up the
commitment to ethical standards.

Time after time, the people of Enron failed to do the right thing. Enron's board of directors voted
to waive key provisions in its code of conduct to allow off-the-books partnerships. Enron
management failed to challenge the ethical basis of these decisions.

In the final analysis, Enron's problem was a lack of accountability to anything except the value of
its stock. This led to a culture of getting the numbers by any means necessary. There was no
concern with the impact of decisions on others and no sense of public accountability.

The best — and likely only sure — way to prevent future Enrons is to instill a culture of doing
the right thing, so deeply imbedded and reinforced at every level of the organization, that
shenanigans have no chance of ever getting started.

We need to educate, nurture and reward employees who make it their business to know what is
happening around them and take action — to seek out and interpret financial data, to ask tough
questions and demand straight answers and, when necessary, blow the whistle on unscrupulous
behavior.

We cannot station ethics police on every corner where there might be potential wrongdoing.
Ultimately, there must be a time and space where human conscience alone must guide our
actions. This must be part of everyone's job description.
ARTICLE 14

Making good ethics decisions means doing good business


Friday, October 11, 2002
Houston Business Journal - by Scott Clark

Make no mistake about it, good business ethics is tough. There may be a little voice inside that
whispers, "If I'm not caught, it didn't happen," or "Why shouldn't I? Everyone else does."

Ethics issues are not always black and white; most fall into a gray area. The head of a business
cannot afford even the appearance of unethical behavior. Consider this ethics quiz I frequently
give my MBA students at the University of Iowa:

1. You run a clothing store and a friend comes in and asks you a favor. He has selected a $900
suit and wants a one-time 50 percent discount. How should you respond?

If you acquiesce, word will spread that your business is cut-rate. If your salespeople witness you
acceding to this request, they might be inclined to make special offers to their own friends. Either
way, your bottom line will be significantly affected.

Now, provide the answers to the rest of my scenarios:

2. Because of past abuses, you put out an edict that the company copier cannot be used for
personal purposes. Your son's Cub Scout leader calls and asks if you could make 50 copies of an
informational sheet for the fundraiser. How do you respond?

3. You are a manager in an electronics firm and have been secretly planning to start your own
company. One of the engineers you were going to ask to join your new start-up bursts into your
office, exclaiming he has just been promoted to engineering manager. How do you respond?

4. You are taking a certification exam next week that will let your business qualify for bidding
on large municipal projects. Because of the press of business, you have been unable to study for
the exam. After work, a friend offers you a copy of the exam which he "borrowed" from the
examiner's office. What should you do?

5. You have a large order of new products ready to deliver to a key customer. You have just
discovered a flaw in the manufacturing process. Even though the product looks okay, it will not
meet a critical performance specification and probably malfunction in the field. However, your
company has severe cash-flow problems and urgently needs the cash from this order. If you ship,
you'll have the cash from your customer before the problem is discovered. What action do you
take?

6. Your company is bidding on a large volume of widgets; the competition between you and
Acme Co. is fierce. You stop by the customer's purchasing agent's office to clarify a point before
submitting your bid. After you ask your question, the purchasing agent leaves the room to get the
information. You notice a copy of Acme's bid lying in plain sight. What do you do?

7. Three months ago you applied for an additional line of credit based on projected sales. Today
you have a meeting with your banker to draw down the first installment against this new credit
line. What your banker does not know is that your largest customer is in financial trouble and has
put a stop order on shipments, inventory is bulging at the seams and you are now cash poor, you
need the funds not for expansion but just to meet payroll. What should you do?

In each of the above cases you know the right answer; nevertheless, you may have reasoned that
the circumstances justify taking an action that would otherwise be seen as less than totally
ethical.

In none of the above cases is a less than totally ethical response justified.

Major ethical problems usually begin with small infractions, but the end result is still the same.
Ethics lapses caused by greed and a desire to take the fast track ultimately result in chaos. At a
minimum you risk lost trust, productivity and profits; at the other extreme you risk the collapse
of your company, incarceration and the kind of lifetime notoriety you would not wish upon your
worst enemy.
ARTICLE 15

An ethics audit is essential for every type of business


Friday, April 9, 2004

Houston Business Journal - by Scott Clark

Is your company looking for candidates to replace a departed executive? Is your business seeking
experienced managers to handle projected growth? Are you in search of venture capital to
expand the business or finance a management buy-out? If any of these situations apply to you, be
advised both the managerial candidates and the financiers will be conducting an ethics audit of
your business as part of their due diligence effort.

Although ethics were important in the past, the recent spate of business scandals has brought
ethics to the forefront. Experienced businesspeople and financiers realize a strong ethics program
is essential for a growing business in any field. If a company is lax in its ethics reinforcement,
one inappropriate decision made by a junior executive can wipe out the company's customers and
stock value overnight.

Ethics is not just about doing what is legally right; more importantly it is about what is morally
right.

To ensure your business is viewed in the strongest possible light by future financiers and
employees, your personal ethics must be beyond reproach. This means you cannot afford even
the appearance of unethical behavior. When it comes to business, past skeletons in the closet
may never go away.

Also, you must ensure that your company has a strong ethics foundation and lives by it. To
pinpoint present deficiencies and potential problem areas, consider performing an audit of your
company's ethics environment. Look for the following:

 Does your business have a zero-tolerance for bad ethics? If not, why? The ethics
philosophy at your business should be "one strike and you are out." Nothing else is
acceptable for an ethical business.
 Does your company have a formal, written code of ethics? If so, is it distributed to all
employees?
 If you have a written code, is there a formal system for reviewing, updating and enforcing
this code? If not, the code will quickly be perceived as an ancient document rather than a
living one.
 Are employees at all levels of the company trained in ethical decision-making? This
means far more than handing them an ethics booklet. Every employee should be required to
participate in an ethics training workshop that emphasizes the ethics ideals of your
business. This training should also emphasize the importance of a strong personal code of
ethics, because an employee with poor ethics is like a rotten apple in the barrel; sooner or
later it will start to spoil the good apples as well.
 Is your ethical training a one-time thing or is it ongoing? If you want ethical behavior to
stay strong, it must be reinforced. Every employee should be required to participate in an
annual ethics refresher course.
 How does your company express to employees its commitment to ethics? Does the
company provide the training and nothing more, or does the company instill in every
worker the mantra that they should consider the ethics guidelines in their manual whenever
they make a decision involving the company? Are there company posters proclaiming the
merits of ethical behavior?
 Are employees encouraged to take responsibility for their behavior? Are they encouraged
to question authority when asked to do something they consider ethically wrong? Are they
actively encouraged to maintain a strong personal code of ethics?
 Do you have an ombudsman or similar confidential channel for employees to voice their
concerns regarding ethics violations without fear of retribution? Is there a formal
committee that considers ethical issues in accordance with the company's written code of
ethics?
 Is ethical misconduct dealt with swiftly, firmly and justly within the company? All
employees, whether executives, managers or other workers, should be treated in the same
fair and impartial manner. There should be no excuses when dealing with unethical
behavior at any level within the company. If employees see a senior manager terminated for
unethical behavior, that action will reinforce their commitment to ethics. Conversely, if
they see the senior manager getting only a slap on the wrist, this inaction could destroy the
ethical foundation you worked so hard to establish.
 Does your company emphasize to all senior leaders the fact that they must be models of
ethical behavior for the rest of the company at all times?

Uncovering existing rotten apples in your business can be difficult. One way to do this is to give
a simple questionnaire annually to all employees. Ask three key questions:

1. How do you rate your personal ethics on a scale of 0 (worst) to 4 (best)?

2. How do you rate your supervisor's ethics on the same scale?

3. How could we improve company ethics?

Share only the collective results with supervisors. If there is a recurring theme of actions that
should be taken by the company or a supervisor who is rated poorly on ethics, take action
accordingly. With supervisors, discuss the issues and get them to commit to a plan of action to
improve their ethics.
If your audit uncovers any ethical deficiencies, correct them immediately. You must maintain the
strongest possible code of ethics if you are to attract the best employees and capital on the most
favorable terms.
ARTICLE 16

Employees share reasons their company is'Best Place to


Work'
Friday, October 13, 2006
Houston Business Journal - by Christine Hall

Getting a paycheck isn't the only reason employees stay at their jobs.

Good benefits, flexible schedules and good leadership are only a few of the important qualities
employees look for at their jobs.

As part of the Houston Business Journal's Best Places to Work program, employees are given the
opportunity to anonymously sound off about what makes their company a great place to work.

The responses are numerous, with many commenting on topics such organization, atmosphere,
career growth and management. Many say their companies are an extension of their family,
while others rave about the unique perks.

For example, one employee writes: "My job is like Frosted Flakes, it's not just good, it's
GREAT."

Organization
"Running a tight ship" didn't become a famous saying for nothing. Employees from Best Places
to Work companies feel the same way about their workplaces. They write:

"Axia Resources is built on a foundation of honesty, integrity and excellence. It truly is a great
place to work."

"I feel the core values of CHRISTUS St. John Hospital are on track in making this a great place
to work. The hospital is smaller than many in Houston which makes it a more personable place
to work."

"CT Industries Inc. is a wonderful company. It has just earned the ISO 9001-2000 rating which is
outstanding in the manufacturing sector. The employees and supervisors interact very well.
Everyone is treated with the utmost respect at all times."
"E&C Engineers & Consultants Inc. is the best place I have ever worked. The annual company
trip with employees and spouses is a great team builder and fun too! High expectations for the
employees and the company is a great motivator."

"I have worked for this company since 1998, and as an individual have grown strong and learned
good work ethics by working in teams, and am currently part of our EGL Eagle Global Logistics
social committee who work to keep employee morale high."

"Enterprise Rent-A-Car is now a global company; however, it still feels family- owned and
-operated. I trust my boss to make good decisions and I cannot imagine leaving this company. I
love being a part of this team."

"FKP Architects Inc. manages to maintain a professional image while permitting casual
relationships between and among management and all employees. It's a fun place to work, even
when working overtime."

"Invensys Process Systems has established a work environment that is professional, yet fun.
Management provides you the latitude to do your work and assume calculated risks."

"Kirksey has been built on a tradition of professionalism and respect for the employees. The
leadership is constantly looking to improve the company, the product and the opportunities for
the employees."

"Rockwell Management Corp. is truly a great place to work. The leaders at our corporate office
brainstorm constantly, even if in small groups, to keep employees motivated for their own
success. Rockwell is known for caring for their employees."

"St. Joseph Medical Center is a place where there is history, yet a strong sense of the future and
providing care that is leading in the industry."

"I am a first-year attorney, and I have found my year at Vinson & Elkins LLP to be challenging
and nurturing. The firm cares about attorney development and feedback. The organization is
large, but it has always felt comfortable and familiar."

Career Growth
"Put me in coach!" is what many employees are saying to their bosses, as companies are giving
them the opportunity to grow and learn in their jobs. Employees write:

"This is a great organization that values its employees and promotes a respectful environment.
CHRISTUS Health allows all employees, regardless of their rank, to contribute their talents and
experience in order to continue the ministry of the organization."

"Costello Inc. is a professional company with a slightly relaxed atmosphere which allows for
individual growth, development and the security to be open with superiors about ideas."
"I have been with Halliburton now for almost two years. The organization has been a great place
to work. I feel very comfortable with the ability to add creative and strategic thinking to my
current position. The organization is very open to creativity."

"NAI Houston is growing, and in that growth they take into consideration how it is affecting the
current personnel and their workload. They are continuously upgrading equipment to make the
workplace more efficient."

"This company is very unique. It is truly hard to describe how very special it is. Everyone has a
say in the growth of Patrick Henry Creative Promotions Inc. We have VISION meetings where
everyone can take part and help make processes different to be more efficient."

"The Methodist Hospital System is a good place to work and build a career. Methodist takes care
of its employees and recognize their efforts and compensate accordingly. I am glad I am working
for Methodist."

"I truly feel that Triad Resources is the best place that I have worked, not only because it is a fun
atmosphere but because the company is constantly coming up with ways to make the employees
feel like they are a valued part of the organization."

"I have worked for Universal Weather & Aviation for 24 years, starting when I was 20.
Throughout my tenure I have been encouraged to think outside of the box and commit to training
that will improve on my weaknesses."

"Walker Engineering is the most rewarding company that I've ever worked for."

"Wells Fargo Bank has a straightforward mission, and I fully understand how my position helps
the company succeed. Based on what I've heard about other financial institutions, I would be
surprised if another bank was able to lure me away from my job at Wells Fargo. In the next five
years I expect to be working for Wells Fargo, although the company has opportunities outside of
my current job that may be more interesting. I fully expect the support of my managers when I
decide to do something else with the bank."

Atmosphere
A company's health culture and inviting atmosphere, both in and out of the office, keeps
employees returning to the office every day. Many employees praised the ability to talk freely to
management as well as the friendly co-workers. Employees write:

"Allen Boone Humphries Robinson LLP is a great place to work because each individual is
supported professionally, technologically, individually and spiritually. ABHR is comprised of a
close-knit group of people who enjoy working together and have a great time doing it!"

"Andrews Kurth LLP really cares about its employees. It has an awesome family atmosphere that
I love. When I leave here at the end of the day, I always feel valued and like I have accomplished
a lot."
"I really enjoying being a part of Comerica Bank. I feel that we are more than just a bunch of
individuals satisfying a company's needs, more a family encouraging others (the customers) to be
a part as well."

"Geriatric Associates of America PA is to date the best employment I have had in my career as a
business development specialist. I feel respected and that my opinion matters. I foresee being
with GAA for the next five years at the least."

"Hearthstone Senior Services is a wonderful team to work with. The senior staff and leaders of
the company always keep all employees in mind and strive for the best."

"KPMG LLP is a great place to work. While our firm, like many, has faced some obstacles in
recent years, the way we pull together to work through these matters is making KPMG an even
better place to be."

"Memorial Hermann Healthcare System is one of a few places one can work in an atmosphere of
high ethical and moral standards. It is a pleasure to work here. There is some flexibility in work
hours and that is important to me."

"I've been very happy since coming to Rice University. I feel strongly that the work
environment, management and co-workers are far superior to conditions I had at other similar
jobs. I also find the ambiance of the institution to be a good match."

"SpawGlass Construction Corp. is an exceptional place to work. Everyone here is treated with
respect, and the upper level management puts people first. Employees are never micro-managed,
and everyone is given the latitude and responsibility to perform their duties."

"I really do enjoy waking up and coming to work at Sun Coast Resources Inc. I have a great
team leader and awesome co-workers. The atmosphere is laid back and people can talk to you on
a personal level."

"This is the only company I have worked for that values and listens to their employees' concerns,
suggestions, etc. Transwestern is very EMPLOYEE FRIENDLY... unlike most -- we are not just
numbers in a group."

"I've only been with Walter P Moore for three months, and I'm an intern, but I enjoy the
collaborative role of management with the employees of this firm. I feel free to share ideas and
ask questions of anyone -- everyone is willing to share their time to help each other out. This is
definitely a very healthy environment to work in, even when things are hectic."

Management
"Leading the way..." managers don't get where they are by just being a good worker, they have a
long list of qualities and a certain charisma that helps them stay cool under pressure and have fun
at the same time. Employees surveyed say they enjoy the interaction with their managers and the
ability to judge their own progress. They write:
"I love Administaff Inc. I have never been treated so well by any other employer. My manager
has the integrity to run the department and the people skills to make you feel as if you're just as
important as any other team member."

"CB Richard Ellis is one of Houston's best places to work because of how dedicated our local
management is to ensuring that our needs are anticipated and met. There is an open door policy
and they are always receptive to what we have to say."

"My employers at Fogarty Klein Monroe are always ready to help an employee in any kind of
difficulty, even their extended family. I know their first words are always, 'How can we help?' "

"There is ongoing and continuous real concern by owners/partners of the company to keep
HireSynergy a best place to work by always listening and by being servant leaders."

"Gay Nord, CEO of Kingwood Medical Center Hospital, has consistently taken the hospital
forward since her appointment as CEO. Her vision and goals for our future are clear and
communicated well to all staff. She is a major reason for the uprising success of the company."

"Although no organization is not without some minor issues, this job is by far the best I have
ever had. I am paid well and treated well. More importantly, the leaders of Legge Farrow
Kimmitt McGrath & Brown LLP value family and allow me to spend time with my family."

"I get a great feeling from my manager because he shows me that he appreciates my efforts and
contribution to the team. All of the people at Occidental Petroleum are extremely professional
and courteous."

"Our leaders at SpawMaxwell Co. set an example for the rest of the company to follow. They
live up to our motto that states to put people first and success will follow."

"I work in a peaceful atmosphere. I believe that is because we have trust in our management
here. Our opinions are important here. Sterling Bank not only says they care but they act like it."

"I feel like a valued employee at Texas Children's Hospital IDS. My immediate leadership team
is very involved in our work and listens to employee's concerns and needs."

"The Sinclair Group is a great place to work -- a place where every individual is valued and
rewarded for their hard work."
ARTICLE 17

Creditors in bankruptcy cases need info and ethics


Friday, October 3, 2003
Houston Business Journal - by Paule Hewlett

It's not just headlines making it appear that corporate bankruptcy is on the rise. The year 2002
saw the filing of 1.5 million personal and corporate bankruptcy petitions, and 12 of the 20 largest
bankruptcy cases in the U.S. have been filed since 2000.

These are some of the statistics cited by Charles A. Beckham Jr., a partner at the Houston office
of Haynes and Boone LLP. In a recent presentation entitled "How do you get to the front of the
line to grab your morsel, yet avoid the slings and arrows of the great unwashed?" Beckham noted
that more businesses than ever will likely end up in bankruptcy proceedings -- as a creditor.

Companies that carefully monitor receivables can often take preemptive action if a customer
appears to be on financially shaky ground. But once a company is named as a creditor in a
bankruptcy case, according to Beckham, its best bet is to be informed and vigilant. With fraud as
the backdrop for many recent high-profile bankruptcies, proceedings begin in an atmosphere of
suspicion.

All the same, the debtor's actions in a bankruptcy case are strictly regulated by law and carried
out under the oversight of the courts. Beckham's presentation focused on creating guidelines for
ethical practices from the creditor's point of view.

The objective is to salvage as much as possible from the situation while avoiding the appearance
of impropriety.

"In the end, whatever agreements or arrangements you make must be approved by the courts.
You just don't want any questions asked," says Beckham, who is board certified in business
bankruptcy law.

The fray and the gray


One of the first gray areas for creditors is the opportunity to accept a preferential payment before
a bankruptcy petition is filed.
While some companies are wary, according to Beckham, there is nothing unethical about
accepting this pre-petition payment. He, in fact, recommends it.

"There is no certainty that the debtor will actually file for bankruptcy; there's always the chance
for a last-minute aversion. Even if the company does file, it may be after the 90-day period
subject to the court's review. Value principles dictate that the company will be better off getting
the money sooner rather than later," he reasons.

Beckham notes that after receiving pre-petition payments from a financially troubled debtor,
creditors can insulate themselves by applying the payment to the most recent shipment of goods
or services. The reason is to build the case that the transfer was made in the ordinary course of
business, which the courts allow.

Once a company formally files for bankruptcy, the court imposes an "automatic stay," which
prevents a creditor from taking most actions to enforce its rights while the company goes through
the bankruptcy proceedings. Any action in violation of the stay -- in other words, trying to collect
on a bill or recover delivered goods -- will be voided and can result in retaliatory action by the
debtor.

The stay applies whether or not a creditor has received notice of the case. Sometimes companies
violate the stay unknowingly because a notice sent to a post office box, for example, was not
processed properly.

"To avoid this type of delay and misunderstanding," summarizes Beckham, "anyone who collects
mail should be trained to forward legal notices to legal counsel, right away."

Raising a profile
Before a bankruptcy case is filed, the conduct of creditors is characterized as "the race to the
courthouse steps." But once a petition is filed (Chapter 7, providing for liquidation of assets, or
chapters 11 and 13, allowing for reorganization), the system is focused on equality and
establishing priority claims.

In what is called the "first-day motion," a company may request permission to use cash collateral
or debtor-in-possession financing to make the payments necessary to keep operating -- such as
those to meet payroll and claims of what the debtor will argue are "critical vendors." The
"doctrine of necessity," establishing which payments are critical, is the agenda for most first-day
motions.

According to Joe Epstein, a specialist in business restructuring and bankruptcy at the Houston
office of Winstead Sechrest & Minick PC, the critical vendor concept has been used in high-
profile bankruptcy cases such Kmart Corp., Continental Airlines Inc. and Just for Feet.

"Just for Feet argued that the store could only stay in operation by selling top brands like Air
Jordan. The result was that one vendor, Nike, was paid several hundred millions of dollars before
other creditors," he notes.
Creditors may try to convince the debtor that they should be listed as a critical vendor, and thus
eligible to "go to the front of the line," but they should realize this necessity must be proved to
the courts. Epstein also cautions, "The critical-vendor concept is controversial, and the courts are
currently grappling with standards. The results will be played out through appeals."

Position of power
In some bankruptcy cases, the U.S. trustee will form a Creditors Committee. The committee is
generally composed of companies representing the largest claims, although companies can opt
not to serve.

Members of the Creditors Committee are charged with representing the interests of all the
unsecured creditors, at the same time preserving the value of the estate. Powers are quite broad;
members are empowered to investigate the conduct and financial condition of the debtor,
participate in formulating a reorganization plan and consult on the administration of the case.
ARTICLE 18

Employers taking steps to match personal values, company


vision
Friday, June 13, 2003

Houston Business Journal - by Jonn R. Brock

Through solid management and strategic opportunities, a mid-sized company prospers and
grows. New products, services and markets are introduced. Hiring accelerates.

As the company's potential outpaces the vision and skill of tenured leaders, a new generation of
managers is brought on board with the charge to take the company to the next level. Pressure
intensifies.

Sound practices are compromised to meet performance goals. Personal financial incentives begin
to undermine the company mission. The organizational culture is gradually poisoned by greed
and deception until one day the company self-destructs.

Sound familiar?

Long before the current crisis in business ethics, there was plenty of talk about corporate values.
In the aftermath of Enron Corp. and WorldCom it could reasonably be concluded that the only
value that really mattered was the dollar value -- often fabricated - on the bottom line.

Most companies, then as now, espoused decent values, and may even enumerated them in a
statement of values. Whether its values are formalized or not, every organization has them, and
communicates those values in the behaviors it accepts, encourages and rewards.

In many cases, however, the values a company "talks" bear no resemblance to the values a
company "walks." This disparity could be called an integrity gap. Many once-great companies,
countless careers, vast fortunes, precious life savings and reputations have plummeted down the
depths of this gap, never to be seen again.
Integrity management
In this cynical age, integrity has become a corporate asset to be managed as diligently as any
other on the balance sheet. In a service and information economy, a company's values and
resulting reputation may be the primary distinction between it and its competitors.

How does a company create a value system, embrace it, demonstrate it and instill it in its
operations, services and relationships? It is the responsibility of company owners and managers,
and it demands careful attention and training.

Integrity management encompasses commitment, accountability, policies, programs, monitoring,


communication and leadership. Clearly articulating your values is the starting point.

Perhaps the most critical aspect of integrity management rests in an organization's interviewing
and employment practices. As has been seen, individual people and their actions have the power
to destroy a values-based culture.

Principles in action
The most effective way to state values is not just as principles, but as principles in action. By
describing the behaviors that a company esteems, a values statement serves not just to inspire,
but helps people actualize their higher instincts.

It tells them not only how to think, but what to do. It is, after all, the actions of individual people
that put a company's values in motion.

Values-based behaviors should thus be stated for the three essential service relationships:

 To serve customers or clients.


 To serve employees.
 To serve the company itself and its shareholders.

Underlying this exercise is the assumption that people want to do the right thing. And they will,
if they are so led. People sustain values.

How can company owners and managers be sure that the people they choose to represent their
values do, in fact, share them as their own? One answer lies in a more thorough, consistent and
revealing approach to interviewing and promotions.

Hiring process
Once the values in a company culture have been pronounced, they must be implemented. One
important way is by hiring people who will uphold those values. Interviewers must be trained to
detect and evaluate not just skills, but ethics. Ethics are not contained on a written resume, but
rather elicited by a set of artful and open-ended questions, consistently applied.
It's a rare organization that views its interviewers as the guardians of the company fortunes.
Interviewing is more commonly viewed casually, as a necessary chore, or even contemptuously,
as a waste of time. Here are several steps to follow to implement values-based interviewing:

 Value interviewing as a positive contribution. Recognize and reward the interviewing


team.
 Train managers in interviewing techniques. Make sure that the right questions are asked
in the most consistent way to yield meaningful comparisons.
 Ask about values. If applicants can't clearly explain their core beliefs, they either haven't
thought about them or don't have them.
 Beware of wordiness that masks overstatement or untruth. Clarity implies mental
discipline and honesty.
 Uncover the "walk." Using hypothetical questions, find out how the applicant would
respond in unethical situations. Probe for past behavior in compromising circumstances.
 Test the "talk." Say, "Tell me what you know about the company." If applicants respond
with a values assessment, it's one indication that they have heard the company's integrity
message and can embrace it for themselves.
ARTICLE 19

Survey shows: Employees recognizing ethical issues

Friday, August 4, 2000


Tampa Bay Business Journal - by Scott Clark

If my e-mail bag is an accurate barometer, readers are very interested in the topic of business
ethics.

Recently I studied a summary of the 1999 National Business Ethics Study conducted by Walker
Information (http://www.walkerinfo.com) and The Hudson Institute. The results were
revealing.

Overall, employees care about the ethical conduct of their employer. They also question the
ethics of many managers.

Employees believe your actions more than your words. Although more than half of the
respondents believe ethical expectations are communicated well within their business, slightly
less than half perceive their leadership is highly ethical.

If workers see unethical management behavior, they are fearful the organization as a whole is
less ethical. As a result, two-thirds of respondents are uncomfortable reporting misconduct for
the following reasons: a belief the organization would not take action; a lack of confidential
means to report the incident; or a fear of retaliation.

But the bad news is reflected in these, some of the worst results by industry sectors:

• The lowest scoring sector in terms of rating company ethics was the transportation industry.
This includes freight companies, commercial-transportation businesses and air carriers.

• The lowest scoring sector in terms of ethics in the workplace were government organizations.
These include local, state and federal governments.

• One-quarter of manufacturing sector workers reported pressure from supervisors to cut corners
on ethics or compliance issues. Also, workers in this sector tended not to believe their managers
helped them interpret and apply ethical values in the workplace.
The good news by industry sectors:

• The financial-services sector scored highest on most measures of organizational ethics.

• Businesses in the technology sector were third-highest overall.

• The insurance industry garnered the top score for not having workplace pressure to cut corners
on ethical or compliance issues.

And there's middle ground, too:

• Although two-thirds of health-services workers had a high opinion of overall ethics, they rated
their organizations below average in "operating by higher standards than required by policies and
regulations."

There was a perception that health-service providers were focused more on compliance than on
following ethical principles.

• The retail industry scored slightly lower than health services.

This low rating was driven primarily by employee theft. However, employees in this sector were
relatively comfortable reporting violations, believing the allegations would be handled
appropriately by management.

• Communications workers rated their sector in the middle on most measures. However, they
rated employers well below average at "never violating ethics to secure profits."

When companies are ranked by size rather than by industry, smaller organizations (less than 100
employees) scored the best; large organizations (2,500 or more employees) were in the middle,
and midsize organizations were the worst.
ARTICLE 20

Ethical bosses more likely to have ethical workers


Friday, March 24, 2000
Phoenix Business Journal - by Michael Weiss

The best way to fill an office with ethical employees, according to experts, is by being an ethical
boss.

"It's not a matter of talking about ethics as much as it is about living them," said Diana
Robertson, an assistant professor in Emory University's Goizueta Business School in Atlanta.
"The model the owner sets is what permeates the rest of the organization."

Large corporations that want to ensure their employees are honest with management, customers
and each other often set up all sorts of formal procedures, from hiring consultants to drafting an
official code of ethics to sending employees to weekend retreats for discussions about moral
matters.

Small companies may not have the same luxuries, but that doesn't mean they can't encourage
ethical behavior. In fact, experts say, they may actually have an advantage. Because small-
business owners are much closer to the rank and file than corporate management, the employer's
behavior has a much greater effect.

"Some people think that employees aren't always paying attention," said J. Wheeler Weber, a
consultant with midtown Atlanta-based Arcanum, a business intelligence and corporate
investigations firm. "They notice everything."

That's the philosophy of Raphael Meloul, owner and founder of Modular Design Works, a
Norcross, Ga., firm that develops medical devices and other products. He knows that as the boss,
employees tend to take their cues from him about how to dress and how long a lunch they can
take.

The same thing goes with ethics, he said. If employees see him doing something dishonest, such
as lying to a customer, they'll believe that kind of behavior is acceptable.

"When you do something unethical, it works its way down," he said. "When I do something,
(employees) see it. And I can tell how they react to it."
Of course, it's easy to say a business owner can make employees act right simply by modeling
that kind of attitude. The challenge is making sure employees see the behavior the employer
wants them to emulate, which can't happen if the owner is in an office with the door closed.

That's why it's also important to talk about ethical matters among employees, Robertson said. It
doesn't have to be preachy; in fact, she said, it shouldn't be.

But if a supervisor grappling with an ethical issue talks about it with employees, they'll feel more
comfortable bringing their struggles out in the open, too.

And once ethical issues are discussed in public, she said, it's easier for employers to get the
message across -- and it's more likely employees will do the right thing.

"If I'm grappling with an issue myself, it helps to be able to talk to someone else who might be in
a similar situation," she said. "The more you can provide an open forum, the better."

Talking about ethics also shows employees that management considers it an important matter,
Weber said. That's why larger companies do things such as write up a code of ethics and hire
expert consultants.

Those things can help, he said. But they mean nothing -- in fact, they can hurt the case -- if
management doesn't back it up with actions. Just as important as having a code of ethics is
enforcing it, he said. Employees know whether the behavior prohibited by the code is really
being tolerated.

"People are smart," he said. "They know if it's a lie."

Still, even small organizations that don't have the time or resources to devote to a formal ethics
effort might do well to spend an hour or so writing up a simple code, Robertson said. That's
because if an employee does something illegal and the company as a whole is in trouble, the
court can consider formal policies -- such as a code -- as mitigating factors, she said.

The code itself can be very basic, simply instructing employees to act honestly in dealings with
customers, suppliers and each other, she said.

Of course, the best way to ensure employees are ethical is to hire ethical people, but that isn't
always easy. Weber and Robertson advise thorough interviews and complete reference checks,
but acknowledge that even the best vetting won't always unearth a problem.

Even honesty tests, most commonly used by retailers to screen workers likely to help themselves
to free merchandise or cash from the register, are of dubious value, Robertson said.

Try to make it clear during the hiring process that ethical behavior is a company priority, and
anything else will not be tolerated, Weber said. If a candidate sees that the business takes it
seriously, he or she may figure it's not a good fit, anyway.
For Meloul, hiring ethical employees is more about following hunches than anything else. The
trick is to listen carefully, then pay attention to the same gut feeling that always is a factor when
picking workers.

"Sometimes you really don't know for a fact, but you get a feeling that someone is just telling
you what you want to hear," he said. "That's a bad sign."
ARTICLE 21

Sound business ethics now more important than ever


Friday, March 13, 2009
Charlotte Business Journal - by Paul Chapman

In these turbulent times, business ethics dominates the front pages and the nightly news. The
concern is both local and global, affecting individuals and organizations from Charlotte to
Shanghai. Consumers, shareholders, regulators and business leaders alike are looking more
deeply than ever at policies and practices that guide business behavior.

That increased scrutiny creates an opportunity for companies to rededicate themselves to doing
the right things in the right way. And the best leaders recognize that building an ethical business
culture starts at the top. It can’t be delegated or contracted out.

A recent KPMG study of more than 5,000 U.S. workers found that pressure to do “whatever it
takes” to achieve business goals continues to be the primary driver behind corporate fraud and
misconduct.

About 74% of those responding said they had personally observed misconduct within their
organizations during the previous 12 months. Roughly half of the respondents said what they
observed “could cause a significant loss of public trust if discovered.”

It is also important to recognize that a weak economic market can magnify the conditions that
give rise to fraud risks. That could lead some individuals to resort to improper behavior,
especially if they think their jobs are in jeopardy if they miss key goals.

That’s the bad news. The good news: The study also found that formal ethics and compliance
programs make a difference, with fewer episodes reported by companies with such programs in
place.

Organizations recognized for instilling strong ethical cultures know integrity must be embedded
into all aspects of the business. And they must engage everyone at all levels.

The most effective ethics and compliance programs are not separate from other business
initiatives, but are deeply ingrained in them. Such programs create an environment in which
every employee feels a personal responsibility for the integrity of the organization.
The survey offers suggestions for companies that are eager to strengthen or create ethics and
compliance programs. Those programs focus on ethics communication and training, provide
multiple channels for reporting possible integrity issues, ensure top executives are role models
for integrity, build on the credibility of first-line supervisors and understand the favorable impact
of ethics and compliance programs on employee perceptions and behavior.

Here’s a look at each of those factors:

•Ethics communication and training: Overall, the surveyed employees said they understood
the values, standards and policies that define acceptable business practices for their positions,
and they had positive views on ethics communication and training programs.

The key is to underscore the benefits of marrying skills training with behavioral training, so
employees link what they do with how they should do it.

•Channels for reporting possible integrity issues: Asked whom they would feel comfortable
reporting misconduct to, employees said their supervisor (78%), local managers (61%), and
peers or colleagues (57%).

Those findings reaffirm the key role first-line supervisors can play in an effective ethics and
compliance program.

Employees cited legal, internal audit, or board or committee functions as groups to which they
would feel least comfortable reporting allegations.

In addition, more than half (57%) of respondents reported they would feel comfortable using a
hot line to report misconduct, up from 40% in earlier surveys. However, only 53% believed they
would be protected from retaliation, and even fewer (39%) believed they would be satisfied with
the outcome if they reported misconduct to management.

•Top executives as role models for integrity: Nearly two-thirds of those surveyed agreed that
their leaders serve as positive role models for the organization and set the right tone.

However, roughly half suggested a lack of confidence that their CEOs are familiar with the
actual practices further down in the organizations.

But 70% agreed that their CEOs would respond appropriately to ethical matters brought to their
attention.

•The credibility of first-line supervisors: On the whole, local managers and supervisors scored
even more favorably than senior executives as integrity role models, suggesting that greater
familiarity corresponds to higher levels of trust and confidence in management.

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