Ethics module2 kerala univer

UNIT II: Ethics Programme - Features and best practices in ethics programme - creating a control system
- compliance orientation Vs value orientation - code of ethics Vs code of conduct - ethics training and
communication - ethics committee - functions of ethics committee – integrity PACT - virtue ethics -
basic concepts – aretology - aretaic ethics - the Nicomachean ethics – the doctrine of means - ethics
audit - ethical dilemma - understanding and resolving an ethical dilemma - ethical decision making –
process - ethical leadership and its importance – whistle blowing – definition – types - ethical dilemma
in whistle blowing ( Case Method)
ETHICS PROGRAMME
A systematic approach to raising ethical awareness of employees, providing guides
and education on ethics and having resources available to assist in identifying and resolving
ethical issues.
 Components of a program
 Code of ethics
 Ethics training for employees
 A means for communicating with employees
 Reporting mechanism
 Audit system
 Investigation system
(Not every program will contain all of these components, and the emphasis on each will vary)
 Compliance Strategy.
 Tries to prevent
o criminal conduct, violation of government regulations, and self-interested behavior by
employees (e.g., conflicts of interest)
 Imposes standards of conduct and tries to compel acceptable behavior
 Relies more on corporation lawyers and compliance officers
 Integrity Strategy
 Seeks to create conditions that support right action
 Communicates the values and vision of the organization
 Aligns the standards of employees with those of the organization
 Relies on the whole management team, not just law and compliance personnel
 Benefits of an Ethics Program
 Prevent ethical misconduct
 Monetary losses and losses to reputation
o Eg: Sears - loss of $60M and customer trust
 Adapt the organization to rapid change

 Regulatory changes, new technologies, mergers & acquisitions, and global competition can
require new ways of doing business
 Managing relations with stakeholders
 Informs suppliers about a company‘s own standards
 Reassures other stakeholders of the company‘s intent
o Three approaches
 Statement of specific rules or standards
o Often called codes of conduct, or statements of business standards or practices
 Statement of core values or vision
o Often called a credo or mission statement
o Johnson & Johnson‘s Credo
 Statement of corporate philosophy that describes the beliefs guiding a particular company
o Hewlett Packard - The HP Way
– An effective program will
 Have compliance standards that are reasonably capable of reducing criminal conduct
 Specifically designate high level managers to oversee the program
 Exercise due care not to delegate major authority to a person known to have criminal
tendencies
 Develop a method of communicating the policies and procedures to all employees
 Take steps to achieve compliance by using monitoring and auditing systems designed to
detect criminal conduct by employees and by having a reporting system where employees
can report criminal conduct by others
 Consistently enforce standards through appropriate disciplinary mechanisms
 Take steps to prevent future occurrences, including modifying the ethics program
FEATURES & BEST PRACTICES IN ETHICS PROGRAMME
• Comprehensive, ongoing risk assessment
• Code/policies designed and branded
• Ongoing, strategized communications
• Dynamic, mixed training strategies
• Self-governing ethical culture
• Compliance widely measured and communicated
The 12 elements of a best-practices ethics program include the following. Each element is
described in reference to the pressure-to-perform scenario.

1. Vision statement. A vision statement defines the long-term, most desirable future state for
the organization. The vision gives employees and managers a first screening test for
decisions. They should ask themselves: ―Will this decision or action move the organization
closer to its vision?‖
2. Values statement. A values statement defines general principles of required behavior. It‘s
the standard against which decisions and actions are evaluated to determine if they meet the
company‘s and employees‘ requirements.
Example: An organization that adopts the simple values of fairness, honesty and integrity
would set only those goals that employees can achieve through honest means, and would
require that employees refrain from ―gaming the system‖ and that communication among all
parties be truthful.
3. Organizational code of ethics. A code of ethics gives organization-specific definitions of
what‘s expected and required. The code of ethics should clarify the organization‘s
expectations. The code also defines the consequences for failure to meet the standard.
Example: In detailing the values of honesty or integrity, the code of ethics would specify
that reporting of sales and work times be accurate and truthful, and that failure to meet this
standard can be cause for dismissal.
4. Ethics officer. An ethics officer ensures that the ethics systems are in place and
functioning. This person monitors the organization to determine if it‘s making a good faith
effort to abide by its stated values, that the code of conduct supports those values and that
violations of those values are prevented or detected and addressed. The ethics officer
usually oversees the ethics communication strategy and mechanisms for employees to
obtain guidance and report suspected wrong doing.
Example: In the pressure-to-perform case, the ethics officer should encourage and receive
communication from employees about the performance standards and determine whether or
not those standards constitute an impetus to violate the organization‘s values and code of
ethics.
5. Ethics committee. The ethics committee oversees the organization‘s ethics initiative and
supervises the ethics officer. It‘s the final interpreter of the ethics code and the final
authority on the need for new or revised ethics policies. Early in the ethics initiative, it also
may act as an ethics task force, creating the infrastructure it will eventually oversee.
Example: The ethics committee receives information regarding any patterns or trends in
employee comments about goal-setting, measurements and rewards, as well as instances of
reported misconduct. It‘s responsible for initiating the organization‘s response to those
patterns and trends, which likely includes a review of the goal-setting guidelines and a test
of the reasonableness of current goals. The committee also initiates steps to reverse the
pressure to violate the code of ethics to meet artificially high performance standards.
6. Ethics communication strategy. If employees are to know what‘s expected of them and
what resources are available to them, the ethics officer must create a cohesive ethics
communication strategy. This strategy ensures that employees have the information they
need in a timely and usable fashion and that the organization is encouraging employee

communication regarding the values, standards and the conduct of the organization and its
members.
Example: Employees require information about what‘s expected and how to safely raise
their concern if the goals, as set, are unattainable by any means that the organization would
condone.
7. Ethics training. Ethics training teaches employees what the organization requires, gives
them the opportunity to practice applying the values to hypothetical situations and
challenges, and prepares them to apply those same standards in the real world.
Example: Ethics training enables employees to recognize the ethical dilemma of
unreasonable goals and ensures they know what resources are available for safely raising
the issue. It also makes it evident to the managers setting those standards that doing so
creates an unacceptable condition in the workplace.
8. Ethics help line. Help lines aren‘t just for reporting unethical conduct. They also make it
easier for the organization to provide guidance and interpretation of its expectations when
the intent of an ethics policy is unclear.
Example: In the pressure-to-perform scenario, a call to a help line alerts the organization to
the problem and ultimately leads to restoring reasonableness to the sales and performance
objectives.
9. Measurements and rewards. In most organizations, employees know what‘s important by
virtue of what the organization measures and rewards. If ethical conduct is assessed and
rewarded, and if unethical conduct is identified and dissuaded, employees will believe that
the organization‘s principals mean it when they say the values and code of ethics are
important.
Example: Appropriate rewards and measures prevent the unreasonable goals that are the
motivation for the lying, cheating and stealing.
10.Monitoring and tracking systems. It isn‘t enough to track and monitor employee
behavior. It‘s also critical to assess the extent to which employees accept and internalize the
organization‘s values and ethics code. Do they agree with their importance and
appropriateness? Do they believe they apply to all employees at all levels?
Example: If employees suspect that managers know employees are cheating to reach goals
and are looking the other way, this may suggest that looking good on the sales reports is
more important to managers than doing the right things in the right ways.
11.Periodic evaluation. It‘s important to assess periodically the effectiveness of any initiative,
especially an ethics program. Is the commitment still there? What has been the impact of
recent changes? Are ethics-related goals and objectives being met? What new challenges are
emerging?
Example: With periodic ethical climate evaluations the pressure to improve sales and
service performance can be anticipated, preventing an ethical mess to follow.
12.Ethical leadership. The bottom line is that ethics is a leadership issue. Leaders set the tone,
shape the climate and define the standards. If managers are trustworthy and trusted, if their
motivations are honorable and their expectations crystal clear, and if they‘re paying
attention to ethics as an integral element of every business decision, then ethical problems
will be rare. Problems arise when the leaders are distracted by other elements of running the
organization and fail to ensure that the ethical systems are in place and are effective.

Example: The pressure-to-perform scenario can develop because managers are sidetracked
by competition and inadvertently communicate that nothing is more important than sales.
The message they should be communicating is that sales, honestly made and honestly
reported, are crucial, but that dishonest sales dishonestly reported serve no one
 Problems with Ethics Programs
 Some evidence that misconduct occurs because of organizational pressures and peer
behavior, not because of ignorance over ethical standards
 This suggests that ethics programs include goal-setting and reward systems
 Ethics programs may be adopted as "window dressing", rather than focus on real
solutions
 Large companies already have "effective" compliance programs - but small companies
might invest too much in them, when other approaches would be better.
CREATING A CONTROL SYSTEM (Developing an Effective Ethics Program)
Controls are often policies and procedures that seek to ensure compliance in and of themselves.
However, a particular system of ethical controls or ―guiding rules‖ is needed to accommodate
organizational change or situations that are not easily foreseen (for which ethical behavior is still very
much needed). Policy and procedure therefore needs to be developed around a variety of actual and
theoretical risks that may be faced by the enterprise. These risks may include criminally serious
employee actions such as theft or fraud as well as equally unethical actions such as working within
expense guidelines, turning up at work on time or making sure that computer systems are properly
backed up.
Two Types of Control Systems That Can Be Created Are:
A) Compliance (obedience) Orientation/Strategy: creates order by requiring that
employees identify with and commit to specific required conduct. It uses legal terms, statutes.
And contracts that teach employees the rules and penalties for noncompliance.
This strategy is based on three interrelated components:
i. Rules: Compliance strategies are centered around strict codes of ethics composed of rules
that set forth minimum thresholds of acceptable behavior. The use of rules to structure
employee action does run into problems due to the gap between rule and application, the
appearance of novel situations, and the impression that it gives to employees that obedience
is based on conformity to authority.
ii. Monitoring: The second component consists of monitoring activities designed to ensure that
employees are conforming to rules and to identify instances of non-compliance. Monitoring
is certainly effective but it requires that the organization expend time, money, and energy.

Monitoring also places stress upon employees in that they are aware of constantly being
watched. Those under observation tend either to rebel or to automatically adopt behaviors
they believe those doing the monitoring want. This considerably dampens creativity,
legitimate criticism, and innovation.
iii. Disciplining Misconduct: The last key component to a compliance strategy is punishment.
Punishment can be effective especially when establishing and enforcing conduct that remains
above the criminal level. But reliance on punishment for control tends to impose solidarity on
an organization rather than elicit it. Employees conform because they fear sanction.
Organizations based on this fear are never really free to pursue excellence.
B) Values Orientation: strives to develop shared values. Although penalties are attached,
the focus is more on an abstract core of ideals such as respect and responsibility. Instead of
relying on coercion, the company's values are seen as something to which people willingly
aspire.
To facilitate comparison, three correlative but different elements to Values-Based or aspirationnal
approaches will be identified.
i. Development of Shared Values: company develops a Statement of Shared Values. These provide
guidelines that replace the hard and fast rules of a compliance code. Statements in values-oriented
codes play a different logical function than statements in compliance codes. "Principles of
Professional/Organizational Conduct" in compliance codes specify circumstances of compliance:
time, agent, place, purpose, manner, etc. These provide sufficient content to set forth principles of
professional conduct as rules that can be violated. This, in turn, allows them to be backed by
punishment for violation. "Ideals of the Profession" (or organization) set forth a community's shared
aspirations. These are pitched at a level well above and beyond the minimum. Communities can and
should define themselves as much by their aspirations as by their threshold standards.
ii. Support for Employees: Since Statements of Values set forth excellences or aspirations, the role of
the organization changes from monitoring and then punishing misbehavior to finding ways of
opening avenues for employees to realize key values in their day to day activity. Excellence is not
something to be reached overnight. It requires rethinking basic motivations, attitudes, beliefs, and
goals. Companies need to identify obstacles to achieving ideals and then develop support structures
to help those who seek to realize ideals. Values-based approaches change from punishing conduct
that falls below the minimum to providing collective support to those who strive for the excellent.
iii. Locking in on Continual Improvement: Continual improvement is the ultimate goal of
corporations oriented toward excellence. The values these "moral ecologies" identify structure and
channel this endeavor. What is needed at this stage is to develop concrete programs and strategies
for identifying obstacles to excellence, removing them, and remaining on track for excellence.

Some companies identify a compliance strategy where they set forth rules that
establish minimum levels of acceptable conduct, monitor compliance, and punish non-compliance.
Others, value-oriented or aspiration-oriented companies, identify core values or aspirations (by
reflecting on community values and finding them embedded in extant codes of ethics), develop programs
and structures to support those who strive for these values, and work to lock in a program of continual
improvement or betterment.
CODE OF ETHICS
A code of ethics is a formal statement that acts as a guide for the ethics of how
people within a particular organization should act and make decisions.
Codes of ethics commonly address such issues as conflict of interest, competitors,
privacy of information‘s, gift giving, and receiving political contributions or business.
The most comprehensive and consists of general statements, sometimes altruistic or
inspirational, that serve as principles and the basis for rules of conduct. A code of ethics
generally specifies methods for reporting violations, disciplinary action for violations, and a
structure of due process.
A good ethical conduct involves:
• Competing fairly and honestly: Businesses are expected to compete fairly and honestly and
not knowingly deceive, intimidate, or misrepresent customers, competitors, clients, or
employees.
• Communicating truthfully: Ethical conduct requires that companies refrain from issuing false
or misleading communications. Businesses should recognize that their communications reflect
their image and therefore refrain from untruthful, offensive and misleading communications.
• Not causing harm to others: Some business executives put their own personal interests ahead
of that of employees and shareholders thereby causing harm to them. Corporate managers can
mislead investors by withholding vital information; they sometimes take advantage of the
investor by using the company‘s earnings or resources for personal gain.
Most large corporations today have developed codes of conduct internally, which are
intended to provide guidance for managers confronting ethical situations and moral conflicts. Such
codes of conduct need to be supplemented by internal systems, such as reward and information systems,
promotion and hiring practices, recognition systems, and organizational culture and communication
systems, that support their implementation.
Strong top management commitment to and communication about values and ethical
conduct is a core element of ethical leadership from the top of the organization. Ethical leadership is

essential to managers and employees at all levels of the enterprise when they are faced with difficult
ethical decisions and moral conflicts. Codes of conduct alone can seldom be sufficient for managers to
come to good decisions unless they are supported by these other aspects of the organization. In addition
to company or organizational codes of conduct, many of which have been developed internally by
companies to articulate their own value systems, a number of codes and principles have emerged
globally to help managers think about their ethical responsibilities. Some of these are quite spare and lay
out fundamental principles, based on globally agreed on documents signed by many nations, such as the
United Nations Global Compact with its 10 core principles or the OECD Guidelines for Multinational
Enterprises. Others are more elaborate and have been developed by business groups or multi sector
alliances to help guide business decision making. Again, as with internal codes of conduct, these
principles are helpful guides but cannot address every unique situation. As a result, codes need to be
supported by the organization's managerial decision making, its culture, its reward systems, and the
communication that exists about ethical practices within the firm.
CODES OF CONDUCT:
A written document that may contain some inspirational statements but usually specifies
acceptable or unacceptable types of behavior. A code of conduct is more similar to a regulatory
set of rules and as such, tends to elicit less debate about specific actions.
• Important to organize certain business activities.
• Based on the core values of company, it‘s mission& vision.
• Basic purpose is to ensure a proper ethical behavior in the conduct of business.
• Code of conduct or what is popularly known as Code of Business Conduct contains
standards of business conduct that must guide actions of the Board and senior
management of the Company.
• Diff companies have diff code of conduct in business.
The Code may include the following:
(a) Company Values.
(b) Compliance with laws, rules & regulations
(c) Respect & honour for human rights.
(d) Avoidance of conflict of interest.
(e) Accurate and timely disclosure in reports and documents that the company files before
(f) Government agencies, as well as in Company's other communications.
(g) Compliance of applicable laws, rules and regulations including Insider Trading Regulations.
(h) Maintaining confidentiality of Company affairs.
(i) Non-competition with Company and maintaining fair dealings with the Company.
(j) Standards of business conduct for Company's customers, communities, suppliers, shareholders,
competitors, employees.
(k) Prohibition of Directors and senior management from taking corporate opportunities for
themselves or their families.

(l) Review of the adequacy of the Code annually by the Board.
(m)No authority of waiver of the Code for anyone should be given
• The Code of Conduct for each Company summarizes its philosophy of doing business.
Although the exact details of this code are a matter of discretion, the following principles have been
found to occur in most of the companies:
— Use of company's assets;
— Avoidance of actions involving conflict of interest;
— Avoidance of compromising on commercial relationship;
— Avoidance of unlawful agreements;
— Avoidance of offering or receiving monetary or other inducements;
— Maintenance of confidentiality;
— Collection of information from legitimate sources only.
— Safety at workplace
— Maintaining and Managing Records
— Free and Fair competition
— Disciplinary actions
To create a code of ethics, an organization must define its most important guiding values, formulate
behavioral standards to illustrate the application of those values to the roles and responsibilities of the
persons affected, review the existing procedures for guidance and direction as to how those values and
standards are typically applied, and establish the systems and processes to ensure that the code is
implemented and effective. Codes of ethics are not easily created from boilerplate. Ideally, the
development of a code will be a process in which Boards and senior management actively debate and
decide core values, roles, responsibilities, expectations, and behavioral standards.
 Model Code of Business Conduct & Ethics
Commitment to ethical professional conduct is a MUST for every employee of the company in all of its
businesses/units/subsidiaries. This code, consisting of imperatives formulated as statements of personal
responsibility, identifies the elements of such a commitment. It contains many, but not all issues,
employees are likely to face. The code is intended to serve as a basis for ethical decision-making in the
conduct of professional work. It may also serve as a basis for judging the merit of a formal complaint
pertaining to violation of professional ethical standards.
It is understood that some words and phrases in a code of ethics and conduct document are subject to
varying interpretations and that any ethical principle may conflict with other ethical principles in
specific situations. Questions related to ethical conflicts can best be answered by thoughtful
consideration of fundamental principles rather than reliance on detailed regulations. In case of conflict,
the decision of the Board shall be final.
 Applicability
This code is applicable to the Board Members and all employees in and above Officers level
All employees must read and understand this code and ensure to abide by it in their day-to-day activities.

 Statement of Values:
Serves the general public and also addresses distinct groups such as stakeholders. Values statements are
conceived by management and are fully developed with input from all stakeholders.
Six values that have been suggested as being desirable for codes of ethics include:
1. Trustworthiness
2. respect
3. responsibility
4. fairness
5. citizenship
These values will not be effective without distribution, training, and the support of top management in
making these values part of the corporate culture.
 Developing and Implementing a Code of Ethics
1. assessing the needs and risks that an organization-wide ethics program must address
2. developing and distributing a code of conduct of ethics
3. conducting training programs for employees
4. establishing and maintaining a confidential service to answer employees' questions about ethical
issues
5. making sure that the company is in compliance with government regulation
6. monitoring and auditing ethical conduct
7. taking action on possible violations of the company's code
8. reviewing and updating the code
 Keys to Successful Ethics Training
1. Help employees identify the ethical dimensions of a business decision
2. Give employees a means to address ethical issues
3. Help employees understand the ambiguity inherent in ethical situations
4. Make employees aware that their actions define the company's ethical posture both internally and
externally
5. Provide direction for employees to find managers or others who can help them resolve ethical
conflicts
6. Eliminate the belief that unethical behavior is ever justifiable by stressing that
a. Stretching the ethical boundaries results in unethical behavior
b. Whether discovered or not, an unethical act is just that
c. An unethical act is never in the best interests of the company
d. The firm is held responsible for the misconduct of its members
 Common Mistakes in Designing and Implementing an Ethics Program
Failure to understand and appreciate these goals is the first mistake that many firms make when
designing ethics programs.

A second mistake is not setting realistic and measurable program objectives. Once a
consensus on objectives is reaches, companies should solicit input through interviews, focus groups, and
survey instruments.
The third mistake is senior management's failure to take ownership of the ethics program.
Maintaining an ethical culture may be impossible if CEO's do not support an ethical culture.

The fourth mistake is developing program materials that do not address the needs of the
average employee. Many compliance programs are designed by lawyers to ensure that the company is
legally protected.
The fifth common mistake made in implementing ethics programs in transferring an
"American" program to a firm's international operations.
A final common mistake is designing an ethics program that is little more than a series of
lectures. In such cases, participants typically recall less than 15 percent the day after the lecture. A more
practical solution is to allow employees to practice the skills they learn through case studies or small
group exercises.
ETHICS TRAINING AND COMMUNICATION
A major step in developing an effective ethics program is implementing a training
program and communication system to communicate and educate employees about the firm‘s
ethical standards.
Training can educate employees about the firm‘s policies and expectations, as well
as relevant laws and regulations and general social standards. Training programs can make
employees aware of available resources, support systems, and designated personnel who can
assist them with ethical and legal advice. They can also empower employees to ask tough
questions and make ethical decisions. Many companies are now incorporating ethics training
into their employee and management development training efforts.
If ethics training is to be effective, it must start with a foundation, a code of
ethics, a procedure for airing ethical concerns, line and staff involvements, and executive
priorities on ethics that are communicated to employees. Managers from every department must
be involved in the development of an ethics training program. Training and communication
initiatives should reflect the unique characteristics of an organization: its size, culture, values,
management style, and employee base. It is important for the ethics program to differentiate
between personal and organizational ethics.
To be successful, business ethics programs should educate employees about
formal ethical frameworks and more for analyzing business ethics issue. Then employees can
base ethical decisions on their knowledge of choices rather than on emotions.
Written standards deter wrong doing and promote:
1. Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of
interest between personal and professional relationships;
2. Full, fair, accurate, timely, and understandable disclosure in reports and documents that a
company files with, or submits to, the Commission and in other public communications made
by the [company];

3. Compliance with applicable governmental laws, rules and regulations;
4. The prompt internal reporting of violations of the code to an appropriate person or persons
identified in the code.
5. Accountability for adherence to the code.
ETHICS COMMITTEE
Codes of conduct are an outgrowth of company missions, visions, strategies and values.
Thoughtful and effective corporate codes provide guidance for making ethical business
decisions that balance conflicting interests.
Codes of conduct need to be living documents that are encouraged and valued at the highest
levels. Board members and senior executives have to set an example for the type conduct they
expect from others. Ethical lapses at the higher levels of management tend to be perceived as
tacit permission to commit lapses at lower levels. Senior management needs to hold itself to the
highest standards of conduct before it can demand similar integrity from those at lower levels.
Writing a code of conduct, supporting it at top levels and communicating it to employees is just
a beginning. Companies should have a committee of independent non-executive directors who
are responsible for ensuring that systems are in place in the company to assure employee
compliance with the Code of Ethics.
An Ethics Committee will be able to provide an overarching view of the how the company does
its business. It will have responsibility for establishing and embedding corporate ethical values,
the ethics policy and code and ensuring and monitoring ethical business practice.
Institutional Ethics Committee
The need for Institutional Ethics Committee (IECs) in medical and research establishments resulted
from the realization that affirms human rights as a prerogative of all members of society. Individual
physicians and research workers may not be able to do what is right in all instances as evidenced by the
number of cases on record.
TYPES
1. Audit committee
2. Nomination committee
3. Remuneration committee
 FUNCTIONS OF ETHICS COMMITTEE:
The oversight process of the Ethics Committee of an organization involves the following areas
to be addressed by it:

1. Review of the definitions of standards and procedures
The Committee should review the organization's areas of operation, the activities that
require a formal set of ethical standards and procedures.
Once the review is complete and any shortcomings have come to light the ethics committee
should assign the creation of revised guidelines to the appropriate personnel including the design
of a formal method for communicating standards and procedures to employees. This method
should ensure that employees both understand and accept the ethics program.
The ethics committee can suggest behaviors to upper management that reinforce the
organization's guidelines.
2. Facilitate Compliance
The ethics Committee has the responsibility for overall compliance. It is the responsible
authority for ethics compliance within its area of jurisdiction It should serve as the court of last
resort concerning interpretations of the organization's standards and procedures. When and if
inconsistencies come to light in this manner, the committee should make recommendations on
improving the existing compliance mechanisms. And, as always, there should be follow-up to
ensure that compliance recommendations have been understood and accepted.
3. Due diligence of prospective employees
The ethics committee should define how the organization will balance the rights of individual
applicants and employees against the organization's need to avoid risks that come from placing
known violators in positions of discretionary responsibility. This includes the oversight of
background investigations on employees/applicants who are being considered for such positions.
4. Oversight of communication and training of ethics programme
The ethics committee should define methods and mechanisms for communicating ethical
standards and procedures. This includes the distribution of documents (codes of conduct, for
example) to ensure that every employee understands and accepts the organization's ethical
guidelines. To make certain that published standards are understood, the ethics committee
should provide regular training sessions as well.
Since communication is two-way, the ethics committee should solicit stakeholder input
regarding how standards and procedures are defined and enforced. In this connection, it is useful
to create ways of providing proof that each employee has received the appropriate documents
and understands the standards and procedures described.

5. Monitor and audit compliance
Compliance is an ongoing necessity and the ethics committee should design controls which
monitor, audit and demonstrate employees' adherence to published standards and procedures.
There should also be mechanisms which check the effectiveness and reliability of such internal
controls.
To warrant that the organization's goals, objectives and plans do not conflict with its ethical
standards and procedures, the ethics committee should develop methods for regular review and
assessment.
6. Enforcement of disciplinary mechanism
Disciplinary provisions should be in place to ensure consistent responses to similar violations of
standards and procedures (as against applying different standards to different employees based
on their position, performance, function, and the like). There should be provisions for those who
ignore as well as those who violate standards and procedures.
7. Analysis and follow-up
When violations occur, the ethics committee should have ways to identify why they occurred. It
is also important that lessons learned from prior violations are systematically applied to reduce
the chance that similar violations takes place in future.
Integrity PACT
The Integrity Pact (IP) is a powerful tool developed by Transparency International (TI) to help
governments, businesses and civil society fight corruption in public contracting & opaque
management of public fund. It consists of a process that includes an agreement between a
government or government agency (‗the authority‘) and all bidders for a public sector contract,
setting out rights and obligations to the effect that neither side will pay, offer, demand or accept
bribes; nor will bidders collude with competitors to obtain the contract, or bribe representatives
of the authority while carrying it out.
An independent monitor who oversees IP implementation and ensures all parties uphold their
commitments under the IP brings transparency and invaluable oversight to all stakeholders in a
contracting process, from the authority to the public.
IPs are legally-binding contracts, breaches of which trigger an array of appropriate
sanctions, including loss of contract, financial compensation and debarment from future tenders.
These act as powerful disincentives to corrupt behaviour, ensuring IPs are never simply

goodwill gestures. Rather, they enable governments to reduce the high cost and the distorting
impact of corruption on public procurement, privatisation or licensing, and to deliver better
services to citizens.
 The Pact represents a written contract between a contracting authority and tenderers in
the procedure for public procurement awarding, which lays out the opportunity of
independent civil monitoring, conducted by independent external observer.
 CONTRACTING AUTHORITY in the IP is a public authority (within the central or local
government) which conducts the public procurement procedure.
 TENDERERS are the other party in the Integrity Pact. Tenderers are all natural or legal
entities entitled to bid for a certain contract implementation
 INDEPENDENT OBSERVER is the third party of the Integrity Pact, which does not
have direct interest in public funds allocation. The Observer should be an independent
non-governmental organization possessing good reputation and professional expertise in
carrying out independent civil monitoring.
A written agreement between the government/government department and all bidders to refrain from corruption
and collusion.
Bidders are required to disclose all commissions and similar expenses paid by them to anyone in
connection with the contract. If the written agreement is violated then the pact describes the sanctions
that shall apply. These may include:
 Loss or denial of contract;
 Forfeiture of the bid or performance bond and liability for damages;
 Exclusion from bidding on future contracts (debarment); and
 Criminal or disciplinary action against employees of the government.
A monitoring system that provides for independent oversight and increased government accountability
of the public contracting process.
 The main goal of the Integrity Pact implementation is to support the efforts of the
public institutions, business sector and civil society in several directions:
 Prevention and counteraction of corruption in public procurement;
 Improved efficiency in public funds management;
 Better conditions for access to public funds by the business.
 Implementation of the IP in public procurement contributes to:
 Enhancing of transparency and integrity of tenders;
 Encouragement of cooperation between public administration and business;
 Early warning and identification of potential challenges;

 Effective civil control over performance of the bidders and the contractor of the public
procurement;
 Effective civil control over performance of the contracting authority;
 Modernization of public administration;
 Promotion of business integrity and ethical standards.
In most cases, monitors are members of civil society or experts appointed by (and reporting to) the TI
Chapter and its civil society partners. The independent monitoring system aims to ensure that the pact is
implemented and the obligations of the parties are fulfilled. The monitor performs functions such as:
• Overseeing corruption risks in the contracting process and the execution of work;
• Offering guidance on possible preventive measures;
• Responding to the concerns and/or complaints of bidders or interested external stakeholders;
• Informing the public about the contracting process‘s transparency and integrity (or lack
thereof).
 Why use an integrity pact?
 Companies can withdraw from corrupting safe in the knowledge that
o A) their competitors have provided assurances to do the same, and
o B) government procurement, privatisation or licensing agencies will follow transparent
procedures and undertake to prevent corruption, including extortion, by their officials
 Governments can reduce the high cost and distorting impact of corruption on public
procurement, privatisation or licensing in their programmes, which will have a more hospitable
investment climate and public support.
 Citizens can more easily monitor public decision-making and their government‘s activities
 Who can use it?
The integrity pact can be used by government officials and agencies, private companies (the bidders)
and civil society. The initiative to include pacts in a public contracting process can come from any of
these actors.
So far, integrity pacts have been led by civil society -mainly through the TI chapters, sometimes with
other civil society partners- which allow them to share the experience of past projects.
 When can an integrity pact be used?
Integrity pacts are adaptable to many settings. They are flexible tools that can be applied to:
 Construction contracts;
 Goods and services supply contracts;

 State asset privatization programmes (the buyer/recipient of state property);
 Consultants (engineering, financial, architectural, for example);
 State licenses or concessions and extraction rights (oil or gas exploration and production, mining,
fishing, logging, for example);
 Government-regulated services such as telecommunications, water supply and waste collection
services.
Whenever possible, an integrity pact should cover the entire project from start to finish; needs
assessment and justification, bidder pre-selection, bidding, awarding the contract and implementation.
 How do integrity pacts work?
1. The starting point is an agreement for the implementation of the pact between the government
procuring agency and the civil society organisation leading the monitoring. This agreement
confirms the political will to implement the pact, defines the contracting processes and describe
the activities, roles and responsibilities of each of the parties involved.
2. Maximum transparency at every phase of the contracting process leading to the award of the
contract and the project‘s implementation. Public hearings and the internet help provide public
access to all the relevant information including: needs assessment, design, bidding documents,
pre-qualification of contractors, bidding procedures, bid evaluation reports, contract terms and
conditions, contract implementation and supervision reports.
3. The content of the integrity pact should be agreed upon by the civil society organizations and the
government. As a contract between the government office inviting the public tender and the
bidders, it should be one of the bidding documents.
4. The main elements of the pact are:
 An undertaking by the government that its officials will not demand or accept any bribes,
gifts etc., with appropriate disciplinary or criminal sanctions in the case of any violation;
 A statement by each bidder that it has not paid, and will not pay, any bribes in order to
obtain or retain the contract;
 An undertaking by each bidder to disclose all payments made to anyone in connection
with the contract in question (including agents and other middlemen as well as family
members etc.);
 The explicit acceptance by each bidder that the no-bribery commitment and the
disclosure obligation, as well as the corresponding sanctions, remain in force for the
winning bidder until the contract has been fully executed;
 Bidders are advised to have a company Code of Conduct (clearly rejecting the use of
bribes and other unethical behaviour) and a compliance programme for the
implementation of a Code of Conduct throughout the company;
 The use of arbitration as a conflict resolution mechanism, and acceptance that the
arbitration panel can decide and impose sanctions;
 A pre-agreed set of sanctions for any violation by a bidder of any part of its commitments
or undertakings within the pact, including (some or all):
o Denial or loss of contract,

o Forfeiture of the bid security and/or performance bond,
o Liability for damages to the principal and the competing bidders, and
o Debarment of the violator by the principal for an appropriate period of time.
The civil society organizations must select the independent monitor(s): The monitor should be
highly respected people of unquestionable integrity, who possess professional expertise in the
area of the contract. The monitor should not have any links to the procuring agency or bidding
companies. The monitor preferably reports directly to the civil society organizations.
 Monitors should have free access to all relevant government documents, meetings and officials,
and to all documents submitted by the bidders. They should review the tender documents, the
evaluation reports, the award selection decision and the implementation supervision reports
(technical as well as financial).
 Monitors regularly inform the leadership of the government office of any corruption risks or
possible irregularities detected. The monitors should suggest preventive/corrective measures to
all parties.
 Where any corruption risks or possible irregularities are reported by the monitor to the
government office and no steps have been taken (or such steps are inadequate) within a
reasonable period of time, then the Monitor is entitled to inform the public and/or the public
prosecutor‘s office about this situation. In addition, the civil society organizations must be
entitled to withdraw from the pact process and explain in a public statement the reasons for the
withdrawal.
 What wider benefits does an integrity pact bring?
 Enhanced access to information, which increases the level of transparency and integrity in public
contracting.
 Greater confidence and trust in public decision-making – foster changes in the perception of
citizens & bidders about the presence of corruption in public procurement.
 Less litigation on procurement processes.
 Contract values that match or are below original budget estimates reducing the cost of public
contracting
 More bidders compete for public contracts
 Induce greater media coverage of anti-corruption activities resulting in increased public
awareness.
 Encouragement of institutional changes such as the introduction of e-procurement systems,
simplification of administrative procedures, use of bidders‘ rosters, effective regulatory action,
and new practices by public officials such as using codes of conduct or ethics agreements..

 What challenges does an integrity pact face?
Lack of real political will:
 Governments should make clear commitments to demonstrate that a pact is not just a show of
transparency. Civil society must follow-up closely to ensure government compliance.
Political changes:
 Building relationships and securing commitment at several levels of government ensures changes
in positions do not undermine a pact.
Limited technical expertise within TI Chapter or civil society group on the sector covered by the
contracting process:
 External experts can support the technical review of the procurement process. Local independent
experts are important, but international experts should fill in if none are available.
Insufficient access to timely and reliable information on the contracting process:
 There should be clear provisions on how and when information should be disclosed, and specify
that non-compliance will be a cause for civil society‘s withdrawal from the monitoring.
Insufficient interest of the media to report on the results:
 The media typically likes stories about scandals more than stories on anti-corruption efforts.
Efforts can be made to build an alliance with a strong actor within the media who understands
the concept of the pact, will champion its work and report on the results of pacts. Training of
journalists is another option.
VIRTUE ETHICS
Basic concepts:
1. Special branch of ethics founded by Plato & his disciple ,Aristotle.
2. It emphasizes the importance of right character among human beings.(i.e. virtue theory
puts an emphasize on character based on virtues.)
3. Virtue ethics is grounded in ―character traits,
4. A man of virtue is always respected & praised because virtue is a special type of
achievement which needs hard work & determination.
5. moral virtues are habits that allows a human being to live with
reason.
6. Aristotelian virtue ethics has two parts.
 First, Aristotle argues that our personal happiness (flourishing) is the ultimate
goal that we should promote.
 Second, he argues that we should learn

 to have habits and behave in ways that lead to our personal happiness.
It is said that moral virtue is obtained and is appreciated as part of a good human being who is
morally high and this is revealed in the habitual behaviour of the person. A person is said to
possess moral virtue when he is inclined to act normally in the way that are the characteristics of
a morally sound person. For instance, honesty is regarded as an attribute of a person who is
morally good.
When a person believes that telling the truth is right and he feels good when he speaks the truth
he is said to be honest by virtue. He habitually speaks the truth and does so because when he lies
he is uncomfortable and therefore, tells the truth out of respect for truth. If a person spoke
truthfully occasionally or spoke the truth with immoral desires, or for wrong motives, in that
case he is not honest. A person cannot be called honest if he lies frequently, or if his motive for
telling the truth was to get people to like him or out of fear. Honest as a moral virtue has to be
acquired and is not just a normal characteristic like beauty or intelligence. Possessing a moral
virtue is worthy of praise because it is like an accomplishment since it needs effort.
Virtue ethics is currently one of three major approaches in normative ethics. It may, initially, be
identified as the one that emphasizes the virtues, or moral character, in contrast to the approach
which emphasizes duties or rules (deontology) or that which emphasizes the consequences of
actions (consequentialism).
.
A brief definition of Virtue Ethics: "Virtue Ethics is a classification within
Normative Ethics that attempts to discover and classify what might be believed of
moral character, and to apply the moral character as a base for one's choices and
actions."
The concepts of virtue ethics derived from ancient Greek philosophy are the following: virtue,
practical wisdom, and eudaemonia (or happiness, flourishing, and well- being).
The general concept behind Virtue Ethics is that it focuses on what the
individual should choose for his/her own personal inward behavior (character) rather than the
individual relying solely on the external laws and customs of the person's culture, and if a
person's character is good then so ought the person's choices and actions be good. There is value
in the ideals of Virtue Ethics, namely the value of directing the individual's attention away from
following popular opinion while placing the attention back upon the individual him/herself.
Virtue: A virtue is a positive trait or quality subjectively deemed to be morally excellent and,
thus, is valued as a foundation of good being.
 Virtues are attitudes or character traits that enable us to be and to act in ways that
develop our highest potential. They enable us to pursue the ideals we have adopted.

Honesty, courage, compassion, generosity, fidelity, integrity, fairness, self-control, and
prudence are examples of virtues frequently cited throughout the world.
 Virtues are personal qualities that provide the basis for the individual to lead a
good, noble, or 'happy' life. The person most associated with virtue ethics is Aristotle, and
he placed the 'greatsoul- man' on a pedestal. The great-soul-man displays those virtues that
were regarded as of the highest order. Virtue ethics is not a system of rules, but rather a set
of personal characteristics that, if practiced, will ensure that the individual is likely to make
the 'right' choice in any ethically complex situation.
 Virtue is a relative concept .it is related to the society, the nature of the state and
social position &responsibility.
 Plato had identified four virtues, those of wisdom, courage, self-control and justice.
 For Aristotle, justice was the dominant virtue, and furthermore liberality (the virtuous
attitude towards money); patience (the virtuous response to minor provocation);
amiability (the virtue of personal persona); magnanimity, truthfulness, indifference (in
relation to the seeking of public recognition of achievement), and wittiness
 The virtue ethical theory judges a person by his character rather than by an action that
may deviate from his normal behavior. It takes the person's morals, reputation and
motivation into account when rating an unusual and irregular behavior that is considered
unethical
 Virtue Ethics has been developed in three main directions:
Eudaimonism
Implies performing one‘s
distinctive function well.
Agent-Based Theory
Emphasizes that virtues are
determined by common sense,
intuitions that we as observers fudge
to be admirable traits in other
people.
Ethics of Care
The ethics argues that along
with justice, important
feminine traits, such as
caring and nurturing should
also be considered while
performing one‘s function

Criticism:
0 Virtues are not enough for enhancing social welfare which depends on some right over action.
0 Virtues are covert qualities. Unless virtues are translated into action, there is no social welfare or
personal improvement or gratification.
0 At times, it becomes very difficult to distinguish between Virtues and values, and to that extent, virtue
ethics loses its importance as a separate branch of ethics.
0 Virtues may be looked upon as vice. For instance, in Aristotle‘s Greece, humility was a vice. But to
Christians, it was a virtue. There is no clear-cut classification of unique Virtues.
0A man may possess some virtues, yet he may be a bad man. For instance, a man may possess courage,
prudence, justice and temperance (the four classic virtues) and yet he may be angry, cruel, nasty and
vengeful.
0Virtue ethics fails to address the dilemmas that arise in applied ethics. For instance, in the case of
abortion virtue ethics does not give any direction.
(First, virtue ethics fails to adequately address dilemmas which arise in applied ethics, such as abortion.
For, virtue theory is not designed to offer precise guidelines of obligation. Second, virtue theory cannot
correctly assess the occasional tragic actions of virtuous people. . . . Since virtue theory focuses on the
general notion of a good person, it has little to say about particular tragic acts. Third, some acts are so
intolerable, such as murder, that we must devise a special list of offenses which are prohibited. Virtue
theory does not provide such a list. Fourth, character traits change, and unless we stay in practice, we
risk losing our proficiency in these areas. This suggests a need for a more character- free way of
assessing our conduct. Finally, there is the problem of moral backsliding. Since virtue theory
emphasizes long- term characteristics, this runs the risk of overlooking particular lies, or acts of
selfishness, on the grounds that such acts are temporary aberrations
One weakness of this ethical theory is that it does not take into consideration a
person's change in moral character. For example, a scientist who may have made mistakes in the past
may honestly have the same late night story as the scientist in good standing. Neither of these scientists
intentionally plagiarized, but the act was still committed.)
ARETOLOGY
 one of the fundamental fields of ethics and moral theology
 An Aretology (from ancient Greek arête, "excellence, virtue") in the strictest sense is a
narrative about a divine figure's miraculous deeds. In the Greco-Roman world,
aretologies represent a religious branch of rhetoric and are a prose development of the
hymn as praise poetry.
 An Aretology is also a "catalogue of virtues" belonging to a person.
 In an even more expanded sense, Aretology is moral philosophy which deals with virtue,
its nature, and the means of arriving at it. It is the title of an ethical tract by Robert Boyle
published in the 1640s.

 Arete - Arete in ancient Greek culture was courage and strength in the face of adversity
and it was to what all people aspired. – being the best you can be.
ARETAIC ETHICS
 Aretaic Ethics - Strength-Centred Ethics
 Emphasizes Virtues (Strengths) and Vices (Weaknesses) of Character
 From the Greek 'aretai' meaning 'virtue' or 'excellence': this Normative Ethical Theory is
more commonly known as 'Virtue Ethics'. As a normative theory, it is usually attributed
to Aristotle, and maintains that normative evaluations are rooted in the character of a
moral agent rather than the consequences of an action ( Consequentialism) or some
intrinsic feature of an action itself (contra Deontological Ethics).
 A dominant understanding of a virtue-based or character-based perspective is a pure
aretaic ethic
 A pure aretaic ethic has two important implications. The first implication is that moral
virtues consist in the possession of robust character traits by ideally morally virtuous
persons. The second implication is that the moral acceptability of an action is, on this
view, to be solely derived from whether or not it represents the expression of a moral
virtue.
THE NICOMACHEAN ETHICS (NE)
Aristotle‘s Nicomachean Ethics (NE) is a comprehensive work on
several types of ethical issues and principles. It is now studied as a part of historical philosophy.
NE might have been edited by his son Nicomachus, or possibly, the work was dedicated to
Aristotle‘s son. The work was published in 350 BC.
The Nicomachean Ethics is the name normally given to Aristotle's best-
known work on ethics. The work, which plays a pre-eminent role in defining Aristotelian ethics,
consists of ten books.
 The NE is a work in practical ethics. I.e., Aristotle explains how we can lead a satisfying
life.
 The NE fits into Aristotle‘s overall philosophy: it is deeply teleological, speaks of the
way in which humans differ from others (a genus-species definition), explains our
happiness (eudaimonia) in terms of our telos/diferentia/function, and provides a way in
which we can actualize our potential.

The Nicomachean Ethics is widely considered one of the most important
historical philosophical works, and had an important impact upon the European Middle Ages,
becoming one of the core works of medieval philosophy. It therefore indirectly became critical
in the development of all modern philosophy as well as European law and theology. Many parts
of the Nicomachean Ethics are well known in their own right, within different fields. In the
Middle Ages, a synthesis between Aristotelian ethics and Christian theology became
widespread, especially in Europe.
The work consists of 10 books on ethics:
Book I It discusses what is good for human beings. In this context Aristotle explains the
meaning of the concept of good & why & how a man can be good. he also explains happiness as
the supreme goal of life.
Book II This book concentrates on the analysis of virtue
 Two kinds of virtue (arete/excellence): intellectual and moral.
 Intellectual virtue can be taught and learned from a book.
 Moral virtue cannot be learned in this way: it requires time and experience and results
from habit (like learning a skill such as piano playing or skating).
Book III It elaborates on some aspects of human virtue including courage, temperance and
generosity. The analysis is continued in Book IV.
Book IV It goes on illustrating some moral virtues like gentleness, truthfulness, wit and charm.
Book V It makes an analysis of justice and fairness, and gives examples of the essentials
elements of just action and behavior.
Book VI This book dwells on intellectual virtue by illustrating his points of View.
Book VII It discusses pleasures and evils, and the situations when pleasure leads you to evil. In
this context, the book gives clarity to ideas of continence and incontinence.
Books VIII & IX It elaborates on friendship which, according to Aristotle, is perhaps the best
virtue. In this connection, he explains the advantages of friendship and, the qualities and
requirements of a good friend.
Book X The book is devoted to a detailed discussion of pleasure and politics. Aristotle believes
that a good life is possible through properly practiced politics.

Lessons from the Nicomachean Ethics
NE explains the highest good in life is eudemonia (well-being or happiness) which can be
achieved in accordance with virtues (excellence) in a sustainable way so that it permeates the
human psyche throughout the life. NE shows how it is possible to be a good or virtuous man.
Virtuous actions are possible through right actions, right habits and right character. The idea is
similar to the philosophy of Buddhism. Like Aristotle, Buddha has also advised you to practice
right understanding, attitude, action and speech.
THE DOCTRINE OF THE MEAN/THE GOLDEN MEAN
The doctrine of the mean is a central concept in Aristotle‘s virtue ethics.
According to the doctrine of the mean, virtue is a mean state between extremes of excess and
eficiency. Aristotle describes this mean state as an ―intermediate relative to us.‖ To find the
mean relative to us is to find the state of character that correct reason requires.
Aristotle - the golden mean/ golden middle way. Moral behavior is the mean
between two extremes - at one end is excess, at the other deficiency. Find a moderate position
between those two extremes, and you will be acting morally.
The Doctrine is Born
Aristotle‘s doctrine of the mean is introduced in Book II of the Nicomachean Ethics (II.2.1104a12-26)
by way of a medical analogy. Here, Aristotle says that we destroy our strength by training too much or
too little. Similarly, when we eat too much or too little, we destroy our health. Excellence of character,
like strength and health, is destroyed by excess and deficiency, but preserved by ―what is
intermediate‖ (mesotetos).
Core Aspects of the Doctrine (Three basic elements)
Aristotle‘s doctrine of the mean consists of three pillars that work together to form a complete
account.
the three core aspects of the doctrine of the mean are:
a. First, virtue, like health, is produced and preserved by avoiding extremes (i.e .a
healthy person is in a balanced state).
For example, one‘s body temperature is neither too high nor too low. Related to ethics, one‘s character
does not go to extremes. For example, one does not overreact to situations, but rather keeps his
composure. Equilibrium is the right feelings at the right time about the right things, toward the right
people, for the right end, and in the right way

b. Second, virtue is a mean relative to us.
The intermediate of an object is unchanging; if twelve is excess and four is deficiency, then roughly
eight is the intermediate in that object. Aristotle proposes something different for finding an
intermediate relative to oneself. Aristotle‘s ethics are not a one-size-fits-all system; what he is looking
for is the mean that is good for a particular individual. For example, watering a small plant with a gallon
of water is excessive but watering a tree with a gallon of water is deficient. This is because different
plants have different needs for water intake and if the requirements for each plant are not met, the plant
will die from root rot (excess) or dehydration (deficiency).
c. Third, each virtue is a mean between two vices, one of excess and one of deficiency.
Virtue is like the mean because it is the intermediate between two vices. On this model a triad is formed
with one vice on either end (excess or deficiency) and the virtue as the intermediate. If one‘s character
is too near either vice, then the person will incur blame but if one‘s character is near the intermediate,
the person deserves praise. Proper participation in each of these three pillars is necessary for a person to
lead a virtuous and therefore a happy life.
The Virtuous Person
According to the doctrine of the mean, virtuous individuals act in a way that lies in a mean between
extremes, as when a person of courage, when faced with danger, chooses to take the course of action
that is neither cowardly nor foolhardy. For the virtuous person, this mean (e.g. courage) is the state in
which feelings are neither indulged without restraint nor entirely suppressed. However, such a state does
not come naturally. Instead, it requires habitual training and rational control of one's feelings. Through
practice, a balanced disposition -- characteristic of the virtuous person - can eventually be achieved.
The doctrine of the mean also assumes a unity of virtues such that it is impossible for two virtues to
conflict with each other. For example, courage never calls for one to act in a way that is unjust.
ETHICS AUDIT
An ethical audit is a thorough formal examination of the labour practices of a particular
workplace or company. It is a verifiable process to understand, measure, report on, and help
improve an organization‘s social and environmental performance.
An ethics audit resembles a financial or operational audit. It involves
interviews with employees and managers, reviews of records and other information, and,
sometimes, observations of processes and practices. Ethical audit measures the cultures and
behaviors of an organisation, and determines the extent to which its values are embedded across
its people and across its processes.

How to Conduct an Ethical Audit
Ethics audits rely on honesty from all employees.
Audits are designed to dig deep into company records to ensure reliability and accuracy in areas
like accounting systems, financial reporting and legal compliance. Audits generally deal with
quantitative, easily measurable data. Ethical issues, on the other hand, are more often qualitative
or subjective in nature. A number of qualitative research techniques make an ethical audit
possible, but an ethical audit still necessarily functions differently from any kind of financial
audit. Considering multiple perspectives to gain a big-picture understanding of a company's
commitment to ethics is the key to an ethical audit.
Generally, an ethical audit happens in 3 steps:
Step 1
 Identify ethical leader
 Assign tasks and responsibilities
Review the company's formal codes of ethics, ethics training programs and compliance policies
for legal and industry guidelines regarding ethics. A commitment to ethics begins with formal
policies in the employee handbook. Although having such policies in place does not guarantee
real-world compliance, it is a vital first step in building a culture of strong ethics, and it can
show how serious management is about ethical issues. Make sure ethics policies cover the full
range of common issues in business, including discrimination, equal employment opportunity,
financial management, sourcing, customer relations and the impact of company operations on
the environment, the community and the world.
Step 2
 Collect relevant information
Look into past breaches of ethics through company records and archived online news sources.
Begin by asking the business owner or an executive to discuss any legal issues the company has
experienced, but do not let on that you intend to investigate on your own. If you find something
the company representative tried to hide, it can be a large red flag pointing to a culture of
dishonesty. When searching past news releases, look for any negative press about the company,
and scrutinize the story for breaches of ethics. If any previous ethical lapses have occurred,
speak with the company owner or an executive about what the company has done to prevent
similar incidents from occurring since then and in the future.
To make this information more measurable, create a timeline listing each past incident of a
public breach of ethics, and analyze the frequency, rate and momentum of the occurrences.

Step 3
 Identify an ethical audit committee
 Analyze the current ethical situation
 Collect and classify information
 Interpret the ethical problems
 Formulating alternative
 Selection of best alternative
 Implementation
Speak with employees regarding their impressions of the company's commitment to ethics. Take
this opportunity to ask them to share their experiences about co-workers, managers and
executives. Make sure all employees know their interviews are confidential and that honest
answers will help to improve their organizations. Insiders know a large amount of information
that the public, the press and government regulators are not aware of. Not every breach of ethics
is illegal, either, and employees can be an insightful source of information on legal breaches of
ethics occurring on a regular basis.
To make this information more quantitative, look for patterns in the responses you receive and
record the number of times specific issues come up. If you find employees frequently speaking
about management's rude treatment of females, for example, note the number of times the issue
came up and calculate the percentage of interviewers who mentioned it.
ETHICAL DILEMMA
Dilemma is a situation in which one has to choose between two undesirable things or course of
action. This is a situation in which to decide and opt for one would result in going against
another.
An Ethical Dilemma is a situation in which one has to make a choice between the
two equally undesirable choices each of which leads to unacceptable or unwanted consequences.
It is important to mention that Dilemma is not confronting choices. It is a situation where two
situations each of which lead to equally undesirable consequences. Thus, an Ethical Dilemma is
a situation that will often involve an apparent conflict between moral imperatives, in which; to
obey one would result in disobeying another. This is called an ‗Ethical Paradox‘ since in moral
philosophy: Paradox plays a central role in Ethics debates. This is also known as Moral
Dilemma.
An ethical dilemma is a situation that involves at least an ethical issue where a
clear decision or a choice becomes problematic because of competing claims or interests. There
may be an ethical contradiction or conflict in the choice to be made. In such a case, the solution
may not lie in the interest of the company or of the decision-maker.

Suppose john has been appointed as an assistant to the manager of a dairy firm, and on
the very first day of his work, he is asked by the manager to mix water in milk and sell it to the
customers. John is an innocent boy. He is shocked by this order because he comes from a
religious family and he does not want to indulge in unethical work. John is in ethical dilemma
now: his ethical principle does not allow him to mix water with milk, but if does not carry out
the order of the manager, may lose his new job which he wants very badly. In this type of ethical
dilemma, it is difficult to take an immediate clear-cut decision. The decision of course is
possible if the person is straightforward mid does not bother about the consequences of his
decision. The problem is that, in many cases, the decision-maker has to consider the possible
consequences of his action.
In an ethical dilemma, the choice has to be made between two desirable/undesirable
situations as John is facing. He does not want either (perhaps) to lose his job or to mix water
with milk In a dilemma, usually there may be two or more than two options or choices. In the
case of an ethical dilemma, the decision rules are not clear-cut and may be of conflicting values!
Eor ethical dilemma, the solution is not unique or universal; it depends to a great extent on the
ethical background and personality pattern of the decision-maker. If John has a weak moral
background, he will obey the timer of his manager and will retain his job.
 A dilemma is a situation where a difficult choice must be made between two or more
options.
 An ethical dilemma is a moral problem with a choice between potential right and wrong
 According to Doug Wallace, ―An Ethical Dilemma exists when one is faced with having
to make a choice among alternatives like: (i) Significant value conflict among differing
interests, (ii) Real alternatives those are equally justifiable, and (iii) Significant
consequences on stakeholders in the situations‖.
 P. Kidder‘s view: ―They are genuine dilemmas precisely because each side is firmly
rooted in one of our basic core values. Four such dilemmas are so common to our
experience that they stand as models, patterns or paradigms. They are: (i) Truth Vs
Loyalty (ii) Individual Vs Community, (iii) Short term Vs Long term, and (iv) Justice Vs
Mercy‖.
 Salient Features of Ethical Dilemma
If one analyses the causes of ethical dilemma, it becomes clear that in the case of dilemmas:
1. Ethical Dilemma involves multiple choices to be followed
2. Ethical Dilemma involves uncertain consequences in both the nature and extent resulting from
choices
3. Ethical Dilemmas produce mixed consequences in the sense that the consequence of one
choice favorable for one may be unfavorable for another. Eg. to terminate 5% employees and

increase salary of remaining 95% employees may be one such dilemma producing mixed
consequences
4. People might be involved directly or indirectly in Ethical Dilemmas. If the superior tells his
subordinate to submit his (superior‘s) false bill and pay it to him, subordinate is indirectly
involved in this Ethical Dilemma.
5. Social cost and private gains are different.
6. No linkage is established between the two alternative courses of actions (choices)
7. Competitive behavior gains predominance in many cases
8. There may be inconsistency between goals
9. Cross cultural value differentials do exist
10. There are same pressures from somewhere.
11. Problem of right choice is the main issue.
12. Very often, the exact impact of the two alternatives may not be known or determined.
 Examples of ethical dilemmas may include the following:
 Your critically ill family member is in the hospital and the doctors and nurses are turning
to you to make medical decisions on the patient‘s behalf. You don't know how to decide what to
do and could use some guidance.
 You are a patient and are too sick to speak for yourself. You are concerned about who
will make medical decisions on your behalf, and whether your wishes will be followed. You
wonder, "What if they disagree about what I would want, or what would be best for me?"
 You are part of the healthcare team and your patient comes from a culture in which it is
considered wrong to tell patients that they are dying. You're unclear how to respond to a family‘s
request to conceal the truth from a dying patient.
 You are a physician and some may think it is time to withdraw life support and let nature
take its course, yet the dying patient‘s family insists that you "do everything possible" to keep
the patient alive. You're unclear how to solve this problem and worry that "doing everything"
might cause the patient pain and discomfort without offering any benefit.
 Types of Ethical Dilemma
Ethical dilemma may be of different types. Some of which are listed below:
i. Ethical dilemma between one ethically right and one ethically wrong alternative.
ii. Ethical dilemma between two ethically wrong alternatives.
iii. Ethical dilemma between two ethically right alternatives.

In the last two cases, the decision-maker has to make a choice on the basis of his
own ethical perception, judgment, background, ethical intensity and needs; such a choice is not
often clear-cut but involves dilemmas in the sense that one may have to decide whether to
choose the more immoral or less immoral option, as the rewards may be different, or, whether to
choose the morally more right one or the less right one, as the pay offs may be different. ―More
right‖ or ―less right‖ is the mental judgments of the assessor.
In the case of two morally wrong situations, the person may choose the one which
brings least harm or injury to the smallest number of people. This may be called the situation of
reverse utilitarianism. Ethical dilemmas are with respect to two situations created by two
institutions or value systems. The typology of dilemma may involve the following situations:
0 Organization vs Persons (Employees)
0 Persons vs Society
0 Local culture vs foreign culture
0 Organization vs Law
0 Organization vs Society
0 Person vs Law
0 Right vs Right
0Wrong vs Wrong
0 Right vs Wrong
Thus the major types of Ethical Dilemmas people face in business include but are not limited to
the following:
1. Organizational Goals Vs Personal Values
2. Organizational Goals Vs Social Values
3. Organizational Practices Vs Personal Beliefs
4. Organizational Profit Vs Production and sale of hazardous products
5. Work Time Vs Personal business
1. Organizational Goals Vs Personal Values
Organizations are run to achieve certain goals through the employees who come from different
backgrounds including different values system. Sometimes there is a mismatch between the
organizational goal and employees‘ value system.
For example, an organization in order to tide over the competition in the market has set a goal to
go for aggressive advertising like ―Smear Campaign‖ while advertising Manager thinks it is
Unethical.

In other words, an Ethical Dilemma emerges when the organization uses methods or
pursues goals unacceptable to the Manager or Executive of the organization.
Eg: Ralph Nader was the victim of a smear campaign during the 1960‘s, when he was
campaigning for car safety. In order to smear Nader and deflect public attention from his campaign,
General Motors (GM) engaged private investigators to search for damaging or embarrassing incidents
from his past. This act was not acceptable to some Managers of GM. In 1966, the ‗New Republic‘ and
the ‗New York Times‘ reported that GM have tried to discredit Nader, through hiring private detectives
to tap his phones and dig his past. Nader sued the company for invasion of privacy and got $ 284,000.
2. Organizational Goals Vs Social Values
Companies face conflict between organizational goals and social values. JOHNSON &
JOHNSON cleared all retail shelves of its Tylenol analgesic when some containers were traced
containing cyanide poison which had caused deaths.
Although company was in no way directly involved in the Unethical practices and,
thus was not responsible for the tragic deaths, yet they opted for proactive approach than the
reactive one to solve the Dilemma of life and death.
3. Organizational Practices Vs Personal Beliefs
Mismatch between the organizational practices and personal beliefs also emerged a cause of
Ethical Dilemma in the organizations. The multi-national nature of organizations leading to
multi- cultural employment has led to cultural or racial differences among the employees which
have at times emerged as an Ethical Dilemma for the organization.
4. Organizational Profit Vs Production and Sale of Hazardous Products
Profit is oxygen to business, hence, business organizations produce and sell products that can
earn profits in such pursuit, and some organizations produce such products which are harmful
and obnoxious for the society. Cigarette and beverage are such products.
Is this activity Ethical? Such a situation is faced with Ethical Dilemma. ITC, United
Breweries Ltd.
5. Work Time Vs Personal business:
Employees lead two lives- home life and work life. Both have different roles and timings.
Ethically, the two different roles should not be mixed or one should not be overlapped with
another. Employees should not use work time for their private or homework purpose. But,
employees use office or work time for their personal works like making phone calls for fixing
doctor‘s appointment, using organization‘s internet for booking railway or theatre tickets or
using phones for talking with relatives and friends.

 Causes and Sources of Ethical Dilemmas
Several sources and causes are responsible for the phenomenon of ethical dilemma. These
sources are:
a. Individual (Individual values may be in conflict with social or family culture).
b. Family (Family values may be in clash with values in the business).
c. Organization/workplace (Organizational culture may be in conflict With personal
values)
d. Society (Social norms may be in conflict with individual norms).
e. Cross-cultural Level (The culture of one country may be in conflict with the cultural
practices another country).
This type of dilemmas is found mostly in international business.
The basic causes of ethical dilemmas are the clash of two situations where one may be right and
Other may be wrong, both may be wrong, or both may be right. A dilemma is the outcome of a
mental perception (psychological) about a critical situation involving choice.
The dilemma may be due to a clash between personal values and the
organizational culture or values. In such a case, it 1s difficult to decide as to which value is to be
sacrificed. .
The dilemma may be due to organizational goals and social (or
legal) standards. Your senior police officer may ask you to give him every month Rs. one lakh
and also urges you to take money from your subordinate officers in the same way. You are told
that he would not check the amount of money that you take as bribes from the cases you
investigate.
The dilemma may be caused by a clash between organization
practices and personal beliefs. For instance, you may not like racial or gender discrimination.
But your boss wants to practice it and continue the trend. .
Pressure from organization may also cause ethical dilemma. The
CEO, your boss, wants you to produce and sell hazardous or adulterated products in an
organized way, which you do not want.
UNDERSTANDING AND RESOLVING AN ETHICAL DILEMMA
(Resolution of Ethical Dilemmas )
There is no clear-cut method to resolve an ethical dilemma. However, the following discussion
can throw an important light in the matter of the resolution of ethical dilemmas.

1. Study the Nature of the Ethical Dilemmas
 If the ethical dilemmas involves right vs. wrong, ethicists will generally recommend the
acceptance of what is right. However, in doing so, one should be prepared to suffer the
consequences. For instance, if You do not follow the order of the manager to do the
unethical thing suggested by him you may lose your job.
 In the case of right vs. right ethical dilemmas, apply the one which is very close to your
core values and is consistent with the accepted ethical standard.
 In the matter of resolving an ethical dilemma where both the alternatives are wrong, it is
better to choose the one which is less damaging to the person, organization or the society.
2. Analyze the Consequences of Each Contemplated Solution
Very often, the following types of ethical dilemmas need resolution:
(i) Individual Gain vs Social Gain
(ii) Truth vs Loyalty
(iii) Justice vs Mercy
(iv) Short- run vs Long-run Gains
a) Rushworth Kidder’s nine step procedure of resolving Ethical
Dilemma
Steps Description
1. Define the problem and identify the moral issues involved in it.
2. Determine who will be affected by your decisions.
3. Collect the relevant information, facts and figures relating to the problem.
4. Use right Vs wrong method to isolate the illegal issues involved in the problem.
5. Make choices between Justice Vs Mercy, Truth Vs Loyalty, Individual Vs Community, and
Short-term Vs Long term.
6. Select a particular approach based on care, rule and end to resolve the Dilemma.
7. Also try to find out whether there is any other solution for the Dilemma.
8. Finally, decide the most suitable approach and take action without delay.
9. Review the decision and, if required, take necessary measures to make the decision more
effective.

Identify the issues, identify the parties – ethical dilemmas rarely categories themselves, so the first
step is to identify the nature of the problem. It is also important to recognize the different stakeholders
involved – who will be affected and how? We might think of stakeholders in progressively larger
groupings, starting first with those immediately affected by a situation or decision, moving through the
relevant institutions (for example university, employer, sponsor) to the communities of social science
researchers, and finally to society more broadly.
Identify options – researchers may be able to respond to ethical problems in a range of ways, and it is
important that possibilities are not discarded prematurely.
Consider consequences – researchers should consider the range of positive and negative consequences
associated with each option:
Who or what will be helped?
Who or what will be hurt?
What kinds of benefits and harms are involved and what are their relative values?
What are the short and long term implications of any decision?
Which option produces the best combination of benefit maximization and harm minimization?
Analyze options in terms of moral principles – investigators need to examine options against moral
principles, such as honesty, trust, individual autonomy, fairness, equality and recognition of social and
environmental vulnerability. In some instances, some principles may be regarded as more important than
others.
Make your own decision and act with commitment – it is important to integrate consequences and
principles to reach an independent, informed, thoroughly considered and justifiable decision. However,
it is possible that all options will yield adverse consequences or violated principles. Ultimately, we may
find ourselves choosing the lesser of several ‗evils‗.
Evaluate the system and yourself – we owe it to our discipline, our colleagues and all those who are
affected by research in our field to reflect on how the dilemma that we faced arose
b) Consequentialist Approach
Under this approach, focus is given on the practical consequences of action or decision taken.
This approach is also phrased as ―No harm, No foul‖. Elucidate types of positive and negative
consequences associated with each of the possible actions to solve the Dilemma.
Answers for the following questions.
1. Who will be helped by your action or decision?
2. Who will be sufferer?
3. What kinds of benefits and harms are involved and what are their relative values?
4. What are the likely short term and long term implications involved in your decision?
c) Deontological approach
Disregarding consequences focus only on action or duty itself. The question to be answered
is:
1. Is an action, in itself, just and right?

In other words, analyze carefully, how do the various actions measure up against moral
principles like Honesty, Fairness, Equality, and Recognition of social and environmental
vulnerability?
d) Common Approach for resolving Ethical Dilemma
5 Steps for resolving Ethical Dilemmas at work:
1. Consult Code of Ethics of the organization.
When faced with Ethical Dilemma, he/she can begin with resolving by consulting own
organization‘s Code of Ethics or Ethics manual. It may provide a back drop on which one to
have a clearer picture of which decision is more in alignment with the Ethical commitments of
the organization.
2. Share the Dilemma with supervisor / leader.
Take advantage of more experienced supervisor. This exercise is especially beneficial for the
front-line employees who generally face a number of Ethical Dilemmas in their jobs.
Discussing and sharing these Dilemmas with supervisors can benefit employees in two ways.
One, this may help in resolving Ethical Dilemma in an appropriate manner. Two, this may bring
employees out of trouble.
3. Discuss Dilemma with other Executives in the Organization.
One of the benefits of such exercise is that we get some very meaningful insights with their far-
reaching implications from the real-life experiences of these executives across the organization.
Such an action strengthens your ability to solve the problem more effectively, whereas other
executives do also appreciate your concern and commitment to making the right decision.
4. Discuss with peers and colleagues
Discuss with peers and colleagues to get more inputs without divulging trade secrets.
5. Acquaint with the related past happening
Check for similar incidents from the past and see how they solved it. Refer articles, search
internet etc. and take points how they tackled it.
How to Make the Resolution Workable?
To sum up the discussion, the following points need to be emphasized:
o The resolution of ethical dilemma should be within the legal framework. It must not go against the
established law of the land.
o The consequences of all the alternatives must be studied properly.

ETHICAL DECISION-MAKING
It refers to the process of evaluating and choosing among alternatives in a manner consistent
with ethical principles. In making ethical decisions, it is necessary to perceive and eliminate
unethical options and select the best ethical alternative.
 Process (Making Ethical Decisions): A 7-Step Path
Making ethical choices requires the ability to make distinctions between competing options.
Here are seven steps to help you make better decisions:
1. Stop and think: This provides several benefits. It prevents rash decisions, prepares us for
more thoughtful discernment, and can allow us to mobilize our discipline.
2. Clarify goals: Before you choose, clarify your short-term and long-term aims. Determine
which of your many wants and "don't want" affected by the decision are the most important.
The big danger is that decisions that fulfill immediate wants and needs can prevent the
achievement of our more important life goals.
3. Determine facts: Be sure you have adequate information to support an intelligent choice.
To determine the facts, first resolve what you know, then what you need to know. Be
prepared for additional information and to verify assumptions and other uncertain
information. In addition:
o Consider the reliability and credibility of the people providing the facts.
o Consider the basis of the supposed facts. If the person giving you the information says
he or she personally heard or saw something, evaluate that person in terms of honesty,
accuracy, and memory.
4. Develop options: Once you know what you want to achieve and have made your best
judgment as to the relevant facts, make a list of actions you can take to accomplish your
goals. If it's an especially important decision, talk to someone you trust so you can broaden
your perspective and think of new choices. If you can think of only one or two choices,
you're probably not thinking hard enough.
5. Consider consequences: Filter your choices to determine if any of your options will violate
any core ethical values, and then eliminate any unethical options. Identify who will be
affected by the decision and how the decision is likely to affect them.
6. Choose: Make a decision. If the choice is not immediately clear, try:
o Talking to people whose judgment you respect.
o Think of a person of strong character that you know or know of, and ask yourself what
they would do in your situation.
o If everyone found out about your decision, would you be proud and comfortable?

o Follow the Golden Rule: treat others the way you want to be treated, and keep your
promises.
7. Monitor and modify: Ethical decision-makers monitor the effects of their choices. If
they are not producing the intended results, or are causing additional unintended and
undesirable results, they re-assess the situation and make new decisions.
ETHICAL LEADERSHIP & ITS IMPORTANCE
According to the Center for Ethical Leadership, ―Ethical leadership is knowing
your core values and having the courage to live them in all parts of your life in service of the
common good.
The following are reflections/questions on your personal journey towards Ethical Leadership:
1. Will you be the same person at work? At home? In the community?
2. Will you have the courage to live out your values when there is pressure to compromise or
rationalize?
3. How do your values contribute to the common good?
‖ In our experience, ethical leadership involves leading in a manner that respects the rights and
dignity of others; a concept that is at times in direct conflict with more traditional models of
leadership. In the past, the main goal of leadership has been to increase production/productivity
and profits. However, in the 21st Century this view has begun to slowly diminish as more
organizational development and human resources experts assert that leaders also have the
responsibility for ensuring standards of moral and ethical conduct. Good leadership then, refers
not only to competence, but to ethics that transform organizations and people‘s lives.
Ethical leadership requires ethical leaders. If leaders are ethical, they can
ensure that ethical practices are carried out throughout the organization. Leaders are naturally in
a position of power both on and off the job, so ethical leadership must focus on how leaders
leverage this power in the decisions they make, actions they engage in and ways they influence
others. Leaders are responsible for influencing followers to perform actions, complete tasks, and
behave in certain manners. Effective leaders also influence processes, stimulate change in
attitudes and values, and amplify empowerment and self-efficacy of their followers, as they
foster the internalization of corporate vision. The nurturing aspect of leadership can also raise an
organization‘s culture and employee‘s values to higher levels of ethical behavior. By
demonstrating ethical leadership we promote a high level of integrity that stimulates a sense of
trustworthiness, and encourages subordinates to accept and follow our vision. Character and

integrity provides a strong foundation for other personal characteristics that direct our ethical
beliefs, values, and decisions.
Ethical leaders are likely to be people-oriented, and aware of how their
decisions impact others. They therefore use their power and authority to serve the greater good
instead of self-serving interests –a ―win/win‖ for employees and the organization. This modeling
serves as a guide and motivator for others to put the needs and interests of the group ahead of
their own. Such engagement creates an intellectual and emotional commitment between leaders
and their followers that makes both parties equally responsible in the pursuit of common goals.
Further characteristics of ethical leaders include: inspiring,
stimulating, and other visionary behaviors that make up transformational leadership. Ethical
leaders also coach cohorts in gaining a sense of personal and professional competence that
allows them to excel while being more resilient, loyal and profitable.
The 4-V Model of Ethical Leadership
The Center for Ethical Leadership recommends a 4-V Model of Ethical Leadership as a
framework that aligns leaders‘ internal beliefs and values with his or her external behaviors and
actions for the purpose of advancing the common good of employees, leaders, organizations and
beyond. The model was created and based on research by Center founder Dr. Bill Grace.
He found out that people who want to become leaders, who make a difference
need to embrace an inner journey of integrity and make an outer commitment to the common
good. Leadership approach begins with this inner journey. Individuals discover and claim their
core values, develop a vision for how the world could be different, find their personal voice for
expressing their vision.
A quick overview of the 4-V Model is as follows
 Values – Ethical leadership begins with an understanding of and commitment to a leader‘s
core values. By discovering the values which make up the core of our identities and

motivators, we begin the process of integrating our unique values with our choices in our
personal, professional, and civic lives.
 Vision – Ethical leadership requires the ability to frame our actions within a picture of ―what
ought to be‖ – particularly in the area of service to others.
 Voice – Ethical leaders must be able to articulate their vision to others in an authentic way that
enlivens them into action.
 Virtue – Ethical leaders strive to do what is right and good. They practice virtuous behavior by
asking ―How are my values, vision and voice in alignment with and supporting the common
good?‖
Three additional elements that are key to the development of Ethical Leadership are:
Service: Connects vision to values, indicating that when our values are tested and tried through
service to others, the latent vision within them is often revealed.
Polis: Is the Greek word for city and the root of the English word, ―politics‖. As we learn to give
voice to our vision in the context of a public act, we are engaged in the art of politics.
Renewal: As voice returns to values, the territory of our work changes to renewal. As we
express our voice in multiple ways, we need to break from the action on a regular basis to
consider if our actions are congruent with our values and vision.
We would add a 5th ―V‖ to this list: VALIDATE – increase the ethical know-how of everyone
in the organization by hiring for ethics and values as well as capabilities, including ethical
behavior in appraisals and firing people who fall short of ethical standards.
7 Steps to Ethical Leadership
(7 lenses: Learning the principles and practices of Ethical Leaderships)
Ethical Leaders have a tremendous impact on how people in their organizations behave and
what they achieve.
Those who succeed in leading ethically not only improve their business and culture, but also
help make a difference in the world.
Following are the 7 steps / actions leaders can take to integrate ethical
conduct into their organizations:
1. Face the complexity involved in making Ethical choices:
Openly discuss the ethical grey areas and acknowledgment the complexity of work life. Involve
others in more of the ethical decisions. Be a leader who talks about the difficult ethical choices,
and help others learn to take responsibility for making ethical decisions carefully.
2. Don‘t separate Ethics from day to day business:
Leaders must make it clear to their employees that ethics is ―the way we operate‖. Always
include ethics or related topics in all meetings.

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