In short, the survey results merely reflect that companies continue to limit their management of business ethics to the mechanics of compliance and ethics programs without consideration for corporate culture.

For example, implementing or revising a code of conduct is obviously good practice and a sign that management takes the conduct of employees seriously; establishing a hotline suggests that management wants to know about improper conduct; and ensuring compliance with Sarbanes-Oxley promotes best practices.

Yet none of these measures, however important, address the underlying problem -- that in situations where employees face pressure to act unethically or see others act unethically, they feel helpless.

To the CEOs out there, the ERC study offers a chance to reflect and ask yourselves, "if there is a serious breach of ethics in my company, would I know about it? Would my employees feel not simply empowered, but deputized? How long would the problem fester or grow until it is addressed?" 

Examining and measuring your corporate culture is the first step in assuring you and your board that these questions are answered in a way that enhances, not erodes, value for all stakeholders.

WORKING VALUES LTD. is a business ethics and training company. Through a variety of products and services, including Web-based compliance and ethics programs, on-site training, video and award-winning ethics games for employees, Working Values aims to align employee behavior with company values. For more information as to how Working Values can narrow your company's Behavior-Standards Gap, visit www.workingvalues.com or contact cgebler@workingvalues.com. For news on ethics in the workplace, visit SmartPros Ethics & Compliance.