Ethics and Compliance Program: From a Witch Hunt to Preaching the Word. A Middle Management Story
Bibliographic record
Abstract
This paper examines how middle managers experienced the implementation and development of an ethics and compliance program (ECP) in a multinational company after a major corruption scandal. Based on semi-structured interviews and archival data, it shows how middle managers responded to the program’s transformation in a context of regulatory reform and intense stakeholder pressure in Brazil. In 2015, the program was characterized by a coercive environment featuring strict rules and procedures, internal investigations, and an unprecedented sanctioning system. It was consolidated through major changes in key organizational processes, especially centralization of procurement processes and segregation of duties. In 2019, middle managers actively participated in a new phase in the program’s development, characterized by an approach that advocated the moral development of employees. Middle managers developed specific practices in response to each of these three phases. This paper proposes a process model of middle managers’ temporal perspective of ECPs following a corruption scandal. The paper contributes to a better understanding of ethics and compliance programs as dynamic processes and to the practices developed by middle management in their development.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.008 | 0.013 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.001 | 0.001 |
| Science and technology studies | 0.019 | 0.027 |
| Scholarly communication | 0.009 | 0.010 |
| Open science | 0.001 | 0.008 |
| Research integrity | 0.004 | 0.008 |
| Insufficient payload (model declined to judge) | 0.003 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".