How to Build an Ethical Culture

This section gives an overview of the main elements of an effective programme along with some pointers for finding out more.

It is the responsibility of the board and senior leaders of an organisation to establish the culture of their organisation. In addition to leadership and example, an ethics based culture will be promoted through the governance of an ethics programme which works to embed ethical values into business behaviours decisions, processes and operations, as well as manage the risk of ethical misconduct.
The starting point for this is the articulation of a set of values reflecting what the organisation stands for and voluntarily aspires to, beyond compliance with the law and regulations. These values are typically expressed in an ethics policy and guidance is provided to employees through a Code of Ethics or similar. They should guide decision making and norms of behaviour.
An ethics programme to embed these values will, as a minimum, consist of training and communication activities. In addition, mechanisms to support high ethical standards will be needed - such as for raising concerns and reporting misconduct and including ethical criteria in recruitment and in performance appraisals, and detailed policies such as Discrimination, Procurement, Bribery and Corruption, Gifts and Hospitality and Conflicts of Interest. Finally, an assurance process must be in place to monitor the effectiveness of the programme and the extent to which the organisation lives up to its values.
In short, for an ethics policy and programme to be effective, every aspect of corporate culture needs to be harnessed to guide and support the organisation and its employees to live up to the ethical values it espouses.
The diagram below sets out the main elements of an ethics programme.

How to ...

Ethical values & codes

The core element of an ethics programme will be a Code of Ethics.

Nine steps to preparing a code

The process for drawing up a code of ethics is critical in maximising its effectiveness.

Communicating ethical values

A communications strategy for the ethics programme aims to raise awareness of the organisation’s values.


Ethics training raises awareness around the code, what is acceptable business practice and where support can be found.

More elements of an effective ethics programme

Additional tools and mechanisms to keep the code alive and support staff to apply ethical values to the work they do.

Monitoring & accountability

The board needs to establish a programme of assurance to understand whether the organisation is living up to its ethical values.

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