In August 2025, I had the opportunity to witness the Great Migration, one of nature s spectacles where millions of wildebeests and zebras cross over from Serengeti to Maasai Mara and back (covering a distance of nearly 1,200 miles and navigating tough landscapes in search of food and fresh water). As an ethics and compliance professional, this experience made me think about how organizations, similar to these animals, navigate challenges, risks, and resistance as they move toward a more ethical, robust culture.

The migration is not a straight line. It s cyclical and dynamic, guided by instinct, lessons learned, and collective movement, much like how behavioral insights and ethical leadership guide each stage of cultural transformation. At every river crossing, collaboration becomes survival; animals rely on the herd for protection very similar to how employees and leaders must support one another to overcome compliance challenges and build resilience.

Compliance programs versus ethical culture

It is a common misconception that the existence of a compliance program within an organization ensures an ethical organizational culture. Organizations such as Enron, Volkswagen, and Lehman Brothers had established compliance infrastructures, policies, procedures, and written codes of conduct. Despite these measures, ethical failures led to catastrophic outcomes, highlighting that the existence of a compliance program and written documentation do not guarantee an ethical culture.

In contrast, organizations like Aflac, Ecolab, International Paper, Kao Corporation, Milliken & Company, and PepsiCo are celebrated as among the world s most ethical companies for 19 consecutive years.¹ These companies demonstrate a culture where ethical dilemmas are actively discussed, leaders role-model ethical behavior, and processes demonstrate transparency in business decision-making.

The real differentiator is a culture of ethics; it supports and sustains compliance, drives transparency, and encourages employees to act with integrity, even when no one is watching. Ethical companies consistently demonstrate that the how matters as much as the what not just following rules but living the organizational ethical principles.

Behavioral insights: Understanding the mind at work

Human thinking is assumed to be perfectly rational. Behavioral insights offer a scientific lens for understanding and influencing workplace decision-making and challenge the assumption of perfect rationality. People often act based on emotions, habits, and the influence of context not objective reason alone. This approach leverages research on cognitive biases (systematic errors in thinking), heuristics (mental shortcuts), and the role of social context (peer influence, group norms) in shaping choices and actions.

A classic example is how leaders may selectively interpret business intelligence or financial data to support their existing beliefs, while ignoring signals of fraud or unethical practices that do not fit established norms. Another example is how managers may unconsciously favor candidates they instantly like, relying on emotional reactions rather than objective criteria, which can lead to unfair or biased hiring and promotions. Such instinctive behaviors can lead to circumventing rigorous evaluation processes.

People predict they will behave more ethically than they actually do. We often believe that, when faced with a decision, we will act honestly and make the right choices. However, at the pivotal moment, our focus can shift; we may act more on impulse just to get things done. Research shows that people often behave as if they possess multiple selves with different, competing interests the want-self versus the should-self. The want-self demands instant gratification while the should-self looks to longer-term interest. The should self dominates during the prediction and recollection phases, but the want self is dominant during the critical action phase.²

The urge to eat a slice of pizza for lunch represents the want, while opting for a salad because it s healthier reflects the should.³ Human beings often rationalize their choices between want and should decisions to remove cognitive dissonance: the psychological discomfort of acting against their own values or long-term interests.

This rationalization can take several forms across everyday scenarios. When someone indulges in pizza instead of choosing a salad, cognitive dissonance arises from the conflict between short-term pleasure (want) and long-term health (should). To resolve this, the individual might rationalize the choice by saying, I deserve a treat because I worked hard today, or claim, One meal won t hurt my diet, thus making the behavior seem acceptable.

As ethics and compliance professionals, leveraging behavioral insights enables organizations to design policies, standards, and guidelines that make doing the right thing easier, more automatic, and more reinforced.

Why measuring ethical culture is critical

According to Dr. Muel Kaptein s research, ethical culture is best seen as the fabric of informal organizational conditions that encourage ethical actions and discourage unethical ones. Measuring this culture is critical to understanding not only what is happening but why it s happening.

Kaptein s work highlights eight dimensions, also referred to as soft controls, for measuring ethical culture. His research provides for the importance of regular, systematic measurement through interviews, desk research, surveys, observational studies, and root cause analyses.⁴

The returns from measuring ethical culture are tangible: increased employee engagement, innovation, superior financial performance, and reduced fraud or misconduct. Measuring isn t a mechanical exercise. Just as it is critical to lay out a map of a terrain before a critical migration to ensure success, measuring ethical culture enables organizations to identify opportunities, assign ownership to identified areas, and provide a benchmark for the future.

The Corporate Ethical Virtues Model: Eight virtues of ethical culture

Kaptein s Corporate Ethical Virtues (CEV) Model identifies eight virtues that serve as both dimensions of ethical culture and practical levers for change.⁵ Each virtue includes an example drawn from real-world incidents that show behavioral interventions professionals could introduce in their own organizations.

Clarity

Clarity is the foundation of an ethical culture. It involves clear, consistent communication about what constitutes ethical behavior, ensuring that employees understand and internalize these expectations. Ambiguous expectations can lead to ethical blind spots, misinterpretation of rules, and even misconduct. Reinforcing ethical norms at key moments makes them more likely to be followed.

A multinational company faced frequent travel expense fraud, including fake receipts and incorrect claims. Despite policy reinforcements and training, the issue persisted. A simple yet effective intervention was introduced. When employees received foreign exchange before a business trip, they were reminded that the money was for business purposes only and that personal and business expenses must be kept separate. Upon their return, before submitting travel expenses, they received a gentle nudge reinforcing that only genuine business expenses should be claimed.

This targeted and timely communication had a remarkable impact: Travel expense fraud dropped by over 60% within a quarter.

One of the most effective ways to embed ethical behavior is through timely nudges small, well-placed reminders that guide employees to make the right choices in critical moments. Clarity isn t just about setting rules; it s about ensuring they are present, understood, and acted upon in daily business decisions.

• Ethics-focused onboarding sessions include interactive exercises or quizzes that reinforce clarity on ethical standards, ensuring new hires understand and internalize expectations.

• Integrate targeted pop-up messages in workflows within digital applications, particularly at critical decision points (for example, when submitting travel expense reports or approving invoices). These nudges can prompt employees to review ethical guidelines and confirm the accuracy and integrity of their actions before proceeding.

Congruency of supervisors and management

The second and third virtues congruency of supervisors and congruency of management are about leading by example: employees look to leaders to set the tone for ethical behavior. People naturally mirror the actions of those in power, making leadership integrity essential for shaping organizational culture.

A retail company was looking to optimize costs. To accomplish this, they proposed requiring sales teams to fly coach rather than business class, which was likely to meet resistance. Instead of enforcing the rule selectively, the CEO led by example, updating the policy so that everyone, including executives, traveled coach. This simple yet powerful act ensured smooth adoption across the company.

Leaders aren t just shaped by culture; they shape it. When they walk the talk, they build trust, drive accountability, and inspire ethical behavior at all levels.

• Encourage leaders to share real-life examples of ethical decision-making during employee town hall or all-hands meetings.

• Organize regular floor walk sessions where leaders interact with teams, acknowledge positive ethical behaviors, and reinforce ethical concepts in person.

Feasibility

The next virtue, feasibility, is about ensuring that employees have the right conditions to achieve their goals ethically. While challenging, specific and measurable goals drive performance, and an obsessive focus on results can lead to unethical shortcuts, also known as tunnel vision.

A car manufacturer prioritized speed and cost over safety. Determined to launch a new model within an aggressive timeline, executives ignored serious safety concerns, leading to fatal accidents. The pressure to meet business targets overrode ethical decision-making, with devastating consequences.

True success isn t just about achieving goals but also about how they are achieved. Ethical organizations ensure that feasibility and integrity go hand in hand.

• Partner with human resources to coach managers on ethics-focused performance reviews. Encourage managers to integrate discussions about the how as well as the what during performance reviews.

• Include ethical-scenario-based training that presents employees with high-pressure situations in which shortcuts may be tempting.

Supportability

Supportability is about creating a workplace where employees feel respected, valued, and involved in decision-making. When employees believe they are treated unfairly or ignored, they may resort to unethical behavior to balance the scales.

In a research lab, a senior lab assistant responsible for critical drug-testing data was denied time off despite years of service and lack of backup support. Feeling pressured and undervalued, the lab assistant falsified test results. This case highlights how lack of organizational support can lead to ethical breaches.

• Schedule regular, structured active listening sessions where leaders intentionally listen without interruption or judgment.

• Conduct brief, frequent employee pulse surveys focusing on perceptions of support, fairness, and involvement in decision-making.

Transparency

Transparency is about self-reflection and accountability. Lack of transparency can lead to severe consequences, as seen in massive accounting fraud cases that resulted in corporate collapse and regulatory reform.

Transparency is fostered through clear responsibilities, regular audits, documentation, and teamwork.

• Shift from rigid rule-based controls to principle-based approaches.

• Publish ethics metrices such as whistleblower cases reported, resolved, and lessons learned.

Discussability

Discussability emphasizes the freedom to express opinions, concerns, and ethical dilemmas at work. Suppressing concerns can lead to blind spots and catastrophic outcomes.

Organizations must actively encourage open dialogue and create a culture where employees feel safe to challenge decisions.

• Organize informal gatherings to discuss ethical dilemmas.

• Curate sessions using real or hypothetical ethical scenarios for group analysis.

Sanctionability

Sanctionability reinforces that ethical behavior must be rewarded and misconduct addressed consistently.

• Ensure transparent disciplinary processes.

• Apply sanctions consistently across departments and levels.

Conclusion

Charting an ethical course in today s dynamic corporate landscape requires more than a mere compliance program. It demands a commitment to understanding what truly drives human behavior. Just as the great migration is sustained by constant adaptation and collective action, building a robust ethical culture requires intentional effort.

Knowledge of behavioral insights plays a key role in measuring ethical culture. As ethics and compliance professionals, we play a significant role in fostering meaningful dialogues, encouraging ethical behaviors, and leveraging organizational data to shape culture.

 

 

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