Business Codes of
Multinational Firms:
What Do They Say?
ABSTRACT. Business codes are an oft-cited man-
agement instrument. But how common are codes
among multinationals? And what is their content? In
an unprecedented study, the codes of the largest
corporations in the world have been collected and
thoroughly analyzed. This paper presents the results
of that study. Of the two hundred largest companies
in the world, 52.5% have a code. More than half
of these codes describe company responsibilities
regarding quality of products and services (67%),
adherence to local laws and regulations (57%) and the
protection of the natural environment (56%). Many
codes make reference to principles governing stake-
holder relations (e.g. transparency (55%), honesty
(50%) and fairness (45%)), corporate core values (e.g.
teamwork (43%)), appropriate conduct among
employees (e.g. discrimination (44%) and intimida-
tion (43%)) and treatment of company property by
employees (e.g. conflict of interests (52%), corruption
(46%) and fraud (45%)). Monitoring compliance with
the code is addressed in 52% of the codes. Based on
this content study, three types of codes are distin-
guished: the stakeholder statute (72%), the values
statement (49%) and the code of conduct (46%). The
results of this inquiry present a benchmark for the
evaluation and development of both individual and
international business codes.
KEY WORDS: business code, business principles,
code of conduct, compliance, ethics management,
international business ethics, mission statement, multi-
nationals, norms, values
Muel Kaptein is professor of Business Ethics and Integrity
Management at the Erasmus University, Rotterdam, The
Netherlands. He also works as a consultant for KPMG
Integrity, where he assisted about thirty companies in the
development of their code of business.
Journal of Business Ethics 50: 13–31, 2004.
© 2004 Kluwer Academic Publishers. Printed in the Netherlands.
Muel Kaptein
Introduction
The interest in corporate social responsibility,
sustainable business practice, corporate gover-
nance, business ethics, and integrity and com-
pliance management has grown markedly in the
past decade (Waddock et al., 2002). It is not only
stakeholders who expect companies to pay
greater attention to norms, values and principles;
companies themselves are acknowledging the
importance of responsible business practice
(Waddock et al., 2002). But what are a company’s
responsibilities? And how can the board and
management ensure that the company meets its
responsibilities? A much recommended manage-
ment instrument to achieve this is a business code
(also referred to as a corporate code of ethics (e.g.
Cressey and Moore, 1983), a code of conduct
(e.g. White and Montgomery, 1980) or an
integrity code (e.g. Petrick and Quinn, 1997)).
Scholars (see for example McIntosh et al., 2002),
international governing bodies (e.g. the United
Nations, the European Union and the
Organization for Economic Cooperation and
Development), business associations (e.g. the
International Chamber of Commerce) as well as
special interest groups (e.g. the International
Labor Organization and Transparency
International) have been calling on companies
to develop their own business codes. But what
is a business code and what is its function?
A business code is a policy document that
defines the responsibilities of the corporation
towards its stakeholders and/or the conduct the
corporation expects of employees (Kaptein and
Wempe, 2002). A code clarifies the objectives the
company pursues, the norms and values it
upholds and what it can be held accountable for.
14 Muel Kaptein

A code aims to reduce the occurrence of
incidents, to improve the extent to which stake-
holder expectations are realized, to boost stake-
holder confidence in the company and to
encourage the authorities to relax regulations and
controls (see, for example, Ethics Resource
Center, 1980; Raiborn and Payne, 1990).
How common are codes among companies?
And what is their content? Many studies have
been conducted into the prevalence of codes in
specific countries (see Table I). Various publica-
tions have also appeared on the content of codes
in specific countries. Research has also been
conducted into the content of business codes of
multinational firms with reference to one or
more issues such as bribery, child labor and
human rights (see Table II).
To date, no research has been conducted to
examine the prevalence and full content of
business codes of the largest corporations in the
world.
This paper presents the results of an analysis of
the codes of the two hundred largest multina-
tional firms. What do they tell us? What are the
most cited issues? Which issues are barely men-
tioned? What wording do companies choose to
express their responsibilities? How uniform and
diverse are the codes? Is there a core set of

TABLE I
Research conducted on the prevalence of business codes

Country Most recent Researcher Research method Percentage

study of codes

United States 1999 Weaver et al. Survey of Fortune 1000 with a 78%
response rate of 26%
Canada 2002 KPMG Canada Survey of largest 800 companies and 77%
200 public sector organizations with
a response rate of 13%
Japan 1997 Nakano Survey of largest 2199 companies 37%
with a response rate of 7.2%
India 2002 KPMG India Survey of largest 800 companies with 78%
a response rate of 20%
South Africa 2002 KPMG Survey of 1026 public and private 71%
South Africa organizations with a response rate of
16%
Australia 1996 Farrell and Cobbin Survey of largest 537 companies with 42%
a response rate of 42%

England 1999 London Business Survey of largest 350 companies with 78%
School and a response rate of 12%
Arthur Andersen
Germany 1999 KPMG Germany Survey of largest 1000 companies 54%
and the University with a response rate of 25%
of Erlangen-Nürnberg
Belgium 2002 KPMG Belgium Telephonic survey of all of the largest 53%
100 companies
Netherlands 2003 Employer association Telephonic survey of all of the largest 54%
VNO-NCW, KPMG 100 companies
and Ethicon
 Business Codes of Multinational Firms 15

TABLE II
Research conducted on the content of codes

Researchers Year Object of research Themes researched

White and Montgomery 1980 30 codes of U.S. companies Several issues

Cressey and Moore 1983 119 codes of largest companies Several issues
in U.S.
Mathews 1987 202 codes of 485 companies in U.S. Several issues
Schlegelmich and Houston 1989 31 codes of the largest 200 Several issues
companies in England
Langlois and Schlegelmich 1990 189 English, French and West Several issues
German company codes
Employer association 1991, 1999 Respectively, 21, 38 and 54 codes Several issues
VNO-NCW, KPMG and 2003 of the largest 100 companies
and Ethicon
Lefebvre and Singh 1992 75 of the largest 500 companies in Several issues
Canada
Farrell and Cobbin 1996 95 codes of the largest 537 Several issues
companies in Australia
Council of Economic 1997 71 codes of 360 companies Sourcing Guidelines
Priorities for Labor Rights
OECD 1998 98 codes of randomly chosen Fair business practice,
companies labor rights, environ-
mental stewardship and
corporate citizenship
ILO 1999 215 codes of multinationals Labor rights
Van Tulder and Kolk 2000 13 international companies in the Several issues
sporting goods industry
Ashridge Centre for 2000 52 business codes of Fortune 500 Human rights
Business and Society companies
Gordon and Miyake 2001 246 codes of international companies Bribery
Kolk and Van Tulder 2002 55 business codes of Fortune 500 Child labor
companies
KPMG Belgium 2002 53 codes of the largest 100 companies Several issues

universal norms that multinational firms uphold
and, if so, how can they be described?
A content analysis of business codes delineates
the responsibilities multinationals proclaim. To be
sure, the existence of codes does not imply that
companies strictly adhere to them (Sims and
Brinkmann, 2003), but an analysis of the content
of business codes nevertheless reveals what kind
of ethics companies claim to uphold. The results
could, among other things, serve as benchmark
in evaluating and developing individual and
international business codes (e.g. the OECD
Guidelines for Multinational Enterprises, the
UN’s Global Compact and the Caux Principles).
16 Muel Kaptein
Clearly, it is not to implied here that the moral
obligation of companies to include an issue in
their codes is directly proportional to the
frequency with which an issue presents itself. The
moral legitimacy of an ethical standpoint is not
determined by numbers (Donaldson and Dunfee,
1999). The frequency with which issues are
included in codes does, however, allow us to
deduce that the more an issue is mentioned, the
greater the number of companies there are who
endorse it. It can thus be asserted that the greater
the frequency with which an issue is addressed
the greater reason a company should have for not
incorporating this issue in its business code.1
An examination of the prevalence of codes and
the issues they deal with subsequently generates
the question of how the similarities and differ-
ences among the codes could be explained. In
this paper, the collected data will be used to carry
out an in-depth analysis of the different code
types that can be found in practice. Is there uni-
formity among business codes with the same
objective and target group and what bearing do
differences in this regard have on the issues that
are addressed? Thereupon, the influence of
cultural and continental divisions on code type
and content will be examined.
This paper aims to give the reader a better
grasp of the content of business codes. The
empirical effectiveness of business codes,
however, falls beyond the scope of this paper (see
for example Schwartz, 2001). The content of
individual codes is not evaluated either.
This paper starts with a discussion of the
methodology of the research conducted. Follow-
ing this, the issues in the analyzed codes are
arranged according to theme and prevalence. On
the basis of this analysis, we distinguish three
types of codes. The paper concludes with an
overview of the most significant findings and a
number of suggestions for companies to improve
their business codes.
Methodology
This study focuses on the two hundred largest
corporations in the world, using the SCOPE
Core Company list (Van Tulder et al., 2001). In
2001, the respective company headquarters were
contacted by phone with the inquiry of whether
the company had a business code. A business
code was defined as an independent, company-
specific policy document which delineates
company responsibilities towards stakeholders
and/or employee responsibilities. Documents that
formulate responsibilities towards a single stake-
holder (e.g. a code for suppliers), a mission state-
ment that merely formulates economic
objectives, or rules of conduct for employees
with regard to a single issue (e.g. a code for the
use of e-mail and the Internet) were excluded
from this definition.
In the telephonic contact, a connection with
the department of Public Affairs or Corporate
Communications was requested. The company
representative was addressed in the official local
language. Since a range of terms are used to refer
to business codes in practice, the company
representative was assisted as much as possible
with synonyms and different descriptions of a
code. If the person in question had doubts, we
asked to be put in contact with a colleague (from
another department). In some cases, we were put
through to Human Resources, Legal Affairs or
Corporate Security. The companies that claimed
to have a code were requested to send us an
original copy. Two companies that claimed to
have a code but did not want to make it public
due to its confidential nature were not included
in the list of companies with a code given that
it could not be verified.
At the beginning of 2002, the managing
directors of the companies that maintained that
they did not have a code were contacted by mail
to establish whether this was indeed the case. The
letters were written in the official language of the
country where headquarters was based. Two
additional codes were eventually received. Finally,
a search was conducted on the web sites of
companies that repeatedly stated that they did not
have a code and other public resources on
company codes were also consulted. This did not
yield any additional codes. The search was ended
on 1 August 2002.
The aim of this approach was to collect as
many codes as possible so that the proportion of
companies with a code could be represented as
 Business Codes of Multinational Firms
reliably as possible. This contrasts with a few of
the studies listed in Table I that have been con-
ducted. Simply approaching companies with a
questionnaire could have an adverse effect on the
reliability of one’s findings. Companies with a
code are more likely to respond with the result
that on the basis of the total response rate, the
percentage of companies with a code could
appear higher than what is actually the case (see
for example the study conducted in England by
the London Business School with a response rate
of 12%).
The Japanese codes that were received were
translated into English by a native speaker and
checked by a second native speaker. This was
followed by a content analysis. In this analysis, an
inventory was made of the different items con-
tained in the codes. The corporate integrity
model developed by Kaptein and Wempe (2002)
served as basis for classification. The model
distinguishes between (1) company responsibili-
ties towards stakeholders, (2) principles governing
stakeholder relationships, (3) corporate values
and (4) employee responsibilities towards the
company. In addition, the codes were analyzed
for the degree to which they contained references
to implementation, compliance and monitoring
along with their length and tone. The analysis
left aside the distinction that can potentially be
drawn between ethical and economical norms
and responsibilities (Robin et al., 1989). It is,
after all, not possible to deduce from the text of
a company’s business code whether the commit-
ment, for example, to deliver high quality
products is motivated by ethical and/or economic
considerations. This is also why this study
employs the concept of business codes rather than
codes of business ethics.
The prevalence, title and size of codes
How many multinational firms, then, have a
code? Of the one hundred largest companies in
the world, 58% have a code. Of the successive
group of one hundred companies, 47% have a
code. This means that of the two hundred largest
multinationals, 52.5% have a business code.
Business codes are most prevalent among U.S.
17
companies, a finding that is consistent with an
earlier study of Langlois and Schlegelmilch
(1990). The U.S. has a long tradition of business
codes (see for example White and Montgomery,
1980). The large number of Japanese companies
in the top 200 and the relatively small propor-
tion of Japanese companies with a code lower the
total percentage of company codes. The preva-
lence of company codes by country is outlined
in Table III.
The vast majority of the analyzed codes (79%)
belong to companies based in the U.S., France,
Germany and Japan. In the analysis below, we
will examine the differences among codes from
the Americas (largely represented by the U.S.),
Europe (largely represented by Germany and
France) and Asia (largely represented by Japan).
The titles of the codes diverge strongly, for
instance, “Standards of Business Conduct”
(Exxon Mobil), “What We Stand For” (BP
Amoco), and “Legal and Ethical Policy” (BTR).
Of all the titles employed, 36% contain the word
“conduct”, 17% “principles/guidelines”, 9%
“ethics”, 6% “values” and 4% “integrity”.
The size of the different codes varies, as pre-
sented in Table IV, from 1 page (e.g. Nichemen)
to 79 pages (3M), and from 50 words to almost
18,000 words.
The content of business codes
In the following section, the content of the codes
of the two hundred largest companies are
analyzed and discussed with reference to (I)
stakeholder responsibilities, (II) stakeholder prin-
ciples, (III) corporate values, (IV) internal
employee conduct and (V) implementation and
compliance. Thereupon, we shall identify the
types of codes that can be distinguished on the
basis of the content analysis that has been carried
out.
I. Stakeholder responsibilities
In its “Global Business Standards”, Sara Lee
declares that “we have a responsibility to our-
selves, to each other, to our consumers, to our
18 Muel Kaptein

TABLE III
Prevalence by country

Country Top 100 Top 101–200 Total

More than 10 companies in top 200

01. United States 071% (17/24) 066% (23/35) 068% (40/59)
02. France 060% (6/10) 033% (4/12) 045% (10/22)
03. Germany 050% (7/14) 038% (3/8) 045% (10/22)
04. Japan 050% (15/30) 027% (8/30) 038% (23/60)
Fewer than 10 companies in top 200
05. Netherlands 100% (1/1) 100% (2/2) 100% (3/3)
06. England/Netherlands 100% (2/2) 00– 100% (2/2)
07. England/United States 100% (1/1) 00– 100% (1/1)
08. Canada 00– 100% (1/1) 100% (1/1)
09. Sweden 100% (1/1) 00– 100% (1/1)
10. Switzerland 100% (3/3) 067% (2/3) 083% (5/6)
11. England 050% (1/2) 100% (3/3) 080% (4/5)
12. Italy 050% (2/4) 100% (1/1) 060% (3/5)
13. South Korea 033% (2/6) 00– 033% (2/6)
14. Venezuela 000% (0/1) 00– 000% (0/1)
15. Mexico 000% (0/1) 00– 000% (0/1)
16. Brazil 00– 000% (0/2) 000% (0/2)
17. Spain 00– 000% (0/3) 000% (0/3)
Total 058% 047% 052.5%

stockholders, to our business partners and to our
communities”. But what are these responsibili-
ties? What kind of responsibilities do companies
embrace? In Table V, the issues that are addressed
in the examined codes are depicted by stake-
holder.
Most corporate codes, whether extensively or
concisely, pay attention to consumers, investors,
employees, society and the natural environment.
Specifying responsibilities towards competitors
and suppliers is significantly less widespread.
Although some issues are frequently referred to
(such as delivering quality and achieving returns)
the terms in which this is stated may differ. The
quality levels companies pledge to deliver to cus-
tomers are subject to a number of qualifications
such as “high quality” (Nestlé), ‘highest quality’
(Merck/HP), “excellent quality” (Coca-Cola)
and “customer’s first choice for quality” (British
Telecom). Greater divergence can be found in

TABLE IV
Number of pages of business codes
 Business Codes of Multinational Firms 19

TABLE V
Responsibilities towards stakeholders

Degree to which it is
mentioned (n = 105)

I. Customers (or: consumers, clients, buyers)

Supplying sufficient/good/high/highest/superior/excellent/reliable/top quality/
original products and services and offering good value 67%
Sustaining or enhancing the health and safety of consumers 35%
Providing reasonable/competitive/fair prices (and payment conditions)
commensurate with quality 34%
Continually improving quality of products and services 28%
Providing products and services at the right place and time and in the right
amount (accurately, timely, continuity) 10%
Preventing misuse/abuse of products 03%
Helping consumers to use products responsibly 02%
Providing customized products for minorities 01%
II. Capital providers (or: stockholders, owners, investors)
Achieving a maximum/superior/satisfactory/sound/competitive/acceptable/
above-the-market-average return on the capital in the long term, in fair
proportion to the market-related risk 41%
Conserving, protecting and (above-the-market-average/maximize) increasing
the owners’/investors’ assets/capital 09%
III. Employees (or personnel, staff, human capital, including applicants and temporary employees)
Encouraging/optimizing personal development/growth/use of talents 40%
Treating employees with dignity/respect 39%
Valuing diversity/equal opportunity 31%
Offering productive/responsible/challenging/pleasant/enriching work and working
environment 23%
Offering good/competitive/excellent terms of employment/compensation 12%
Providing stable and secure job opportunities 09%
Making the best possible use of each person’s skills, abilities and knowledge 09%
Conforming to sound labor standards 08%
Refraining from child labor 04%
Creating/enabling/guaranteeing a balance between work and private life 02%
IV. Suppliers, joint ventures, contractors and distributors
Ensuring equal opportunity 14%
Seeking mutually beneficial/long-term relationships 12%
Paying competitive market prices in timely manner 06%
Making reasonable demands 03%
20 Muel Kaptein

TABLE V (Continued)

Degree to which it is
mentioned (n = 105)

V. Society (or local community)

Observing, both directly and indirectly, all relevant local laws and regulations 57%
Being a good corporate citizen through charitable donations, educational and
cultural contributions, and employee participation in community and civic affairs 36%
Enhancing the quality of life/contributing to sustainable development/improvement 18%
Respecting human rights/dignity (of those affected by the activities) and
promoting them wherever practicable 11%
Supporting public policies and practices that promote human development and
democracy 8%
Supporting/participating in local initiatives that promote peace, security,
diversity and social integration. E.g. collaborating with community organizations
(for example government agencies and industry groups) dedicated to raising
standards of health, education, product safety, workplace safety and prosperity 7%
Recognizing government’s legitimate obligation to society (legitimizing
government authority) 6%
Doing business with stakeholders who do not systematically violate national and
international social standards 4%
Abandoning commercial activities in countries where it is made impossible to
promote/respect human rights 2%
Setting an example in countries where human rights are seriously and
systematically violated 2%
Adopting practices that permit the transfer and rapid diffusion of technologies and
know-how 2%
Timely payment of taxes 1%
VI. Competitors
Refraining from seeking access to competitors’ assets through improper means 21%
Refraining from casting competitors in a bad light or criticizing them publicly 2%
VII. Natural environment (health, safety and environment)
Preventing/preserving/restoring the natural environment or treating the
environment with due care 56%
Offering safe, clean, orderly and healthy working conditions; eliminating/
preventing injuries/incidents 49%
Preventing/limiting/reducing/controlling negative environmental impacts such
as the direct and indirect pollution of soil, water and air, noise, creation of waste
products and use of hazardous materials 31%
Collecting and having waste processed separately and re-using or recycling it where
possible 21%
Using energy and other natural resources effectively and prudently/efficiently 20%
Preventing incidents 16%
Promoting development of environmentally friendly products 10%
Supporting research and development of environmental technologies 7%
Preventing harm to animals and helping to optimize animal welfare 2%
 Business Codes of Multinational Firms 21

the level of returns to shareholders: “acceptable” TABLE VI

(Shell), “sufficient” (Hewlett Packard), “satisfac- Stakeholder principles
tory” (Philips), “superior” (Ito Yokado Group),
“best possible” (Merck), “excellent long term” Extent to which
(British Telecom) and “maximize long term” it is cited
(n = 105)
(BP). With respect to the natural environment
and competitors, there is greater textual unifor- 01. Transparency 55%
mity. The terms in which companies express 02. Honesty/truth 50%
their position towards society are more diverse. 03. Fairness/impartiality 45%
A few examples include “a harmonious rela- 04. Trust 23%
tionship with society” (Ito Yokado Group), 05. Empathy/respect/diversity 20%
“contributing to the well-being of society” 06. Stimulating stakeholders to
(AT&T), “benefit humankind” (Bayer), “major raise concerns 19%
contribution to development of society” 07. Accountability 18%
(Deutsche Telekom), “betterment of society” 08. Dialogue/open communication 14%
(Coca-Cola), “meeting legal obligations” (Fiat) 09. Equality 12%
and “being a good corporate citizen” (Toshiba). 10. Responsiveness 11%
11. Keeping promises 10%
Striking is that when the results are analyzed
12. Coherence/uniformity 04%
by continent, references to environmental 13. Freedom/autonomy of
responsibilities appear 45% more in European stakeholders 03%
than they do in American codes. Responsibilities
towards competitors are referred to 52% more
in American codes than in European as well as
Asian codes.
honesty, dialogue, and responsiveness) is men-
tioned most. For example, Nestlé “. . . invites
II. Stakeholder principles government officials, health professionals and
consumers to draw its attention to any Nestlé
In addition to articulating stakeholder interests, infant formula marketing practices in developing
a code can also communicate and elaborate on countries which they consider are not in con-
the principles the company upholds. Stakeholder formity with the above commitment” and BT
principles are general requirements for company states that it will “. . . use [its] values and prin-
and employee conduct: they govern the rela- ciples in dialogue with other organizations . . .”.
tionship between company and stakeholders Comparing the most frequently mentioned
(Kaptein and Wempe, 2002). Table VI depicts the principles in the business codes by continent
most cited stakeholder principles. shows that American codes specifically empha-
Stakeholder principles generally do not receive size the principle of honesty (64% in comparison
as much attention as stakeholder interests. with 45% in European and 38% in Asian codes);
Transparency (55%), honesty (50%) and fairness European companies place relative more emphasis
(45%) are the most cited principles. Fairness, for on the principles of transparency (68%, compared
example, is referred to in connection with the to Asian 54% and American companies 52%) and
selection of suppliers, the distribution of benefits the principle of empathy (30%, compared to
and burdens and the assessment of employee Asian 21% and American companies 11%); and
performance. As Merck declares “. . . we treat Japanese companies place somewhat more
our suppliers with honesty, fairness and respect”. emphasis on the principle of trust (29%, in
Shell applies fairness also to its competitors: contrast with American 22% and European
“. . . to compete fairly . . . will not prevent companies 17%). The principle of fairness is
others from competing freely . . .” Good stake- mentioned less often in American codes (35%)
holder communication (e.g. transparency, than in European (50%) and Asian (46%) codes.
22 Muel Kaptein

III. Corporate values The core values cited in the codes diverge
strongly. Merck, for example, asserts that “. . .
Apart from stakeholder principles which pertain we strive to create an environment of mutual
specifically to stakeholder relationships, organi- respect, encouragement and teamwork . . .”
zations also express their core values in a code. while AT&T states that “We treat each other
Core values refer to those qualities a company with respect and dignity . . .” The most often
deems desirable and which should ground all cited values are teamwork (43%), responsibility
business conduct and outcomes (Kaptein and (33%), open communication (29%) and innova-
Wempe (2002)). Table VII presents a summary tion (29%). Noteworthy is that the value of effec-
of the organizational values that can be found in tiveness is seldom mentioned explicitly. Shell is
the examined codes. one of the exceptions in asserting that “The most
important contribution . . . to the social and
TABLE VII material progress of countries . . . is in per-
Core values of/within the organization forming basic activities as effectively as possible.”
American codes make comparatively less mention
Extent to which of values than do European codes. Open com-
it is mentioned munication can be found in 35% of the European
(n = 105) codes, while it amounts to 25% in American
codes. European codes mention teamwork 1.5
01. Teamwork/mutual support/ times more often than do Japanese and American
interdependence/co- codes. Humility, harmony, dedication, innova-
operation/team-spirit 43%
tion, creativity and team spirit are largely found
02. Responsibility/
conscientiousness 33%
in business codes of Asian origin. Innovation and
03. Open communication 29% creativity, for example, are respectively men-
Innovation, creativity, tioned 73% and 46% more in Asian codes than
pioneering 29% in American and European codes. By contrast,
05. Customer oriented 19% the value responsibility/conscientiousness can be
06. Flexibility 17% found just as often in American (30%) as in Asian
07. Efficiency 16% (35%) and European codes (33%).
08. Professionalism 14%
Entrepreneurship 14%
Pride/dignity 14% IV. Internal conduct
11. Loyalty 13%
12. Motivation/enthusiasm/
Business codes can also clarify what is expected
energy/spirit/encouragement 12%
13. Participation 11%
of employees in their engagement with one
14. Shared purpose/unity 10% another and their treatment of organizational
15. Exchanging ideas/learning 09% assets. Contrary to the categories discussed above,
Independence 09% the latter refers to employee conduct versus the
17. Consistent and unequivocal company as opposed to employee conduct on
public image 08% behalf of the company (Mathews, 1987). Table
18. Effectiveness 06% VIII provides an overview of the items referred
Productivity 06% to in this area.
20. Cost-awareness 05% Many codes include a diverse range of rules
21. Discipline 04% of conduct employees must obey among them-
Diligence/perseverance/ selves (particularly discrimination (44%) and
dedication 04%
intimidation (43%)) and with respect to the
23. Courage/daring 03%
24. Harmony 02%
company. Most forms of conduct listed in
25. Humility 01% Table VIII such as engaging in fraudulent prac-
tices, leaking confidential information and sexual
 Business Codes of Multinational Firms 23

TABLE VIII
Employee conduct towards the company and among themselves

Extent to which Extent to which

it is mentioned it is mentioned
(n = 105) (n = 105)

I. Corporate funds IV. Authorities

Adherence to sound financial No conflicting side-line
accounting principles 46% activities/conflict of interests 52%
No fraud 45% No corruption or bribery 46%
No diversion of funds Prohibition or restriction on
(embezzlement) 19% acceptance of gifts 47%
No misuse of funds for No favoring of family and
personal gain 18% friends 34%
No misuse of funds for
business purposes 16% V. Corporate time
Correct handling of expense No alcohol and drug use 17%
returns 08% No private surfing on the inter-
No unjustified billing of hours 07% net during working hours 03%
Sufficient effort 02%
II. Corporate equipment Keeping to stipulated times 01%
Proper use of equipment and No unjustified calling in sick 01%
goods 29% No arms/weapons in the
Protection and conservation of workplace 01%
equipment and goods 18%
No theft of business equipment VI. Staff
or goods 18% No discrimination 44%
Prohibition of or restriction on No intimidation/harassment/
taking business equipment threatening 43%
home for private use 17% Treating one another with
Prohibition or restriction on respect 35%
private use of means of No sexual harassment 26%
communication 14% Treating one another fairly 20%
No neglect of maintenance 03% No unwelcome or unsolicited
physical and verbal sexual
III. Corporate information advances 16%
No leakage of confidential Respect for privacy 14%
information (like trade No racism or racist
secrets) 50% insinuations 12%
No use of insider information No verbal abuse 11%
when trading shares of No physical violence 11%
other securities 44% No tasteless/obscene jokes/
No unauthorized use of access gestures or material 10%
codes 10% No bullying 10%
No gossiping/ridiculing/
insulting 06%
No favoritism 03%

intimidation are prohibited. The norms formu- invitations is mostly subject to certain conditions,
lated in the codes diverge most with respect to for example, that the value is below $50 (GTE)
the acceptance of gifts. Acceptance of gifts or or “purely symbolic” (Fiat), that their acceptance
24 Muel Kaptein
is “always agreed with the supervisor” (Deutsche
Telecom), “a social courtesy” (NTT), that the
“company officer or his/her delegate [has]
approve[d] its acceptance” (Kodak), that it is
“generally accepted business practices of one’s
country and industry” (Sara Lee) or that its
purpose is “to create goodwill” (Xerox).
V. Implementation and compliance
A quarter of the codes make reference to
implementation of the code. GTE for instance,
points out the central role of managers: “GTE
supervisors have an additional responsibility for
maintaining a climate in which legal and ethical
business conduct is the norm; communicating to
employees the seriousness of GTE’s commitment
to such conduct; encouraging open discussion
of employees’ business concerns; accepting and
processing reports filed by employees of possible
misconduct; and, never compromising GTE’s
standards to achieve a goal or objective, no matter
how important that goal or objective seems at the
moment.” GTE also refers to a Business Conduct
Line for employees with questions about inter-
pretation and compliance with the code.
Some 52% of the codes indicate that compli-
ance with the code is monitored. British
Telecom, for instance, sheds light on its moni-
toring practices as follows: “We are committed
to communicating, measuring and appropriate
Figure 1. Frequency of type of codes
reporting of our performance against these
principles.”
Profiles of business codes
The analysis thus far (in keeping with most
scientific analyses of codes) has treated business
codes as a uniform concept. The question,
however, is whether the diversity in the codes’
content is not (partly) the result of the type of
code individual companies have in mind. On the
basis of the collected and analyzed codes, we can
distinguish three clusters of codes: (1) the stake-
holder statute/business principles, (2) the values
statement and (3) the code of conduct. 72% of
the codes formulate responsibilities towards stake-
holders (the so-called stakeholder statute or
business principles), 49% express the corporate
core values in a coherent manner (the so-called
values statement) and 46% set down norms and
rules for employee conduct (the so-called code
of conduct).2 A number of codes integrate two
or even three approaches. Each type is elaborated
on in Figure 1. The types of corporate codes
differ, among other things, in focus (for internal
and/or external use), level of abstraction, size,
use of pronoun and attention to compliance.
Based on a content analysis of codes of
business in the U.S., Mathews (1987) concludes
that U.S. companies are more concerned with
conduct against the company than on behalf of
 TABLE X
Type of codes

Focus Objects Level of Size Use of Tone Compliance Countries

abstraction personal paragraph
pronoun

Stakeholder Internal and Responsibilities Mostly high A single to Often first Predominantly Mostly, in Especially
statute/ external use and principles a few pages person plural descriptive terms of European
business towards e.g. external (46%) and
principles stakeholders reporting and Asian
mechanisms (40%)
for complaints companies
of stakeholders

Values Primarily for Organizational Mostly high A single to Often first Predominantly Hardly Especially
statement internal use values a few pages person plural descriptive Asian
and to a lesser (47%) and
degree for European
external use (32%)
companies
Business Codes of Multinational Firms

Code of Primarily for Desirable Mostly A few to Often Predominantly Largely, in Especially
conduct internal use employee detailed many pages second or prescriptive terms of U.S.
conduct third person e.g. sanction companies
singular mechanisms (53%)
and whistle-
blowers
procedures
25
26 Muel Kaptein
the company. From this study, it would indeed
appear that codes of conduct are a particularly
American phenomenon. Asian and European
companies, however, choose for a stakeholder
statute/business principles or a values statement
more often than do American companies.
Mathews’s conclusion with respect to American
codes is also only a partial reflection of the
present state of affairs. Many American codes
(74%) address stakeholder responsibilities, stake-
holder principles and/or, to a lesser extent, core
values. As this is often (64%) accompanied by a
detailed explication of the norms and rules for
employee conduct in regard to the company, the
latter often overshadows the rest (at least as far
as number of words and visual impact are con-
cerned).
Calculating anew the frequency with which
issues are referred to by code type shows that
more uniformity can be found especially among
codes of conduct. For example, the percentage
of codes of conduct that address fraud, bribery,
use of confidential information and upholding
proper social norms between employees increase
by a factor of 1.8 compared to the total per-
centage of business codes that refer to these
items.3 Of all the codes of conduct, 91% address
these issues. Regarding business codes which can
be defined as values statements, much variation
can still be found in the corporate values that
are mentioned.
Conclusion
This paper consisted of three steps. First, we
made an inventory of the codes of the two
hundred largest companies in the world. Second,
we analyzed the content of the collected codes.
Finally, we examined to what extent the content
of the codes can be related to the type and origin
of codes.
It was found that 58% of the hundred largest
companies (and 52.5% of the two hundred largest
companies) in the world have a code of conduct.
On the one hand, this figure can be viewed as
positive: more than half of the largest multi-
national firms acknowledge and define their
responsibilities, principles, values and/or norms
in a written policy document. On the other
hand, almost half of the largest multinational
firms – at the time of this study – do not have
a code.
Although a business code is not a statutory
requirement, it would appear advisable for com-
panies who do not have a code to (re)consider
whether it might be desirable to develop and
introduce a business code (Schwartz, 2002). As
more companies adopt a code, those who refrain
from doing so will increasingly be confronted
with stakeholders who will want to know why
a code is not viewed a desirable instrument to
manage ethics, integrity and social responsibility.
This study did not examine the reasons com-
panies may have for not adopting a code. A
follow-up study could focus on this question and
examine to what extent companies have ethically
justifiable reasons for not having a code.
This paper has shown that both similarities and
differences can be found in the content of codes,
both with respect to responsibilities towards
stakeholders, stakeholder principles, corporate
values, as well as conduct against the company.
Codes generally describe the responsibilities a
company assumes with respect to employees, cus-
tomers, capital providers and society as a whole.
In general, companies do not employ opposing
norms. They specifically differ in what they
include and exclude from their codes and the
wording that is used (for instance in terms of
levels of commitment).
Finally, this paper has shown that an impor-
tant determining factor in the content of a code
is the target group the company has in mind:
external and/or internal stakeholders. In the case
of the former, the code will focus mostly on
responsibilities towards stakeholders and the
principles that apply. In the case of the latter,
the code will mostly formulate rules for conduct.
If the analyzed codes are grouped according to
type, uniformity in content increases markedly.
The diversity in the content of corporate
codes (also within countries) is not necessarily a
negative sign. It could very well be an indica-
tion of the authenticity of the codes in the sense
that companies draw up codes to suit their par-
ticular circumstances as opposed to merely
copying those of other companies, model codes
 Business Codes of Multinational Firms
or codes of international institutions. At the same
time, a number of topical social issues such as
human rights receive slight attention in the
codes.
This study offers a benchmark for companies
to assess their codes against other corporate codes
and the items they address. As companies become
more international, comparisons with the cor-
porate codes of companies in the countries where
they do business become more desirable.
Stakeholders judge the quality of individual
business codes partly with reference to the quality
of other corporate codes in that country. For
example, in an Asian country, a typically
American code of conduct could be regarded as
too comprehensive and forceful while the
business principles of a European company could
be viewed as too ambitious and abstract.
The benchmark that is presented in this paper
is neither a proposal for a model code nor does
it suggest that uniformity among business codes
is necessarily desirable. The benchmark gives
companies and stakeholders cause for examining
the reasons why a company does not take a stand
on a given issue. If a company decides to address
an issue in its code, it is important that it uses
its own words and tailors it to its own circum-
stances. This overview is especially useful for
companies who do not have a code but who
would like to develop such a policy document.
One of the first steps in developing a code is to
decide on the type of code the company deems
fitting (a stakeholder statute/business principles,
a values statement and/or a code of conduct), the
issues it elects to address and the terms in which
the code will be shaped.
The benchmark offers stakeholders support in
questioning companies on the content of the
code: Why does your company include issue X
but not issue Y? Why do you, as company, for-
mulate it like this and not like other companies
do? Why do you not mention, for example, fair
play, knowing that 45% of companies do? For
international institutions that have issued a
standard for corporations (e.g. the UN and the
OECD) this overview offers an aid in evaluating
their own standards on comprehensiveness and
the extent to which companies have adopted
their standard. The more companies embrace a
27
given issue, the more reason exists for other
companies to ask themselves why they have
omitted it.
By performing a periodical analysis of the
content of business codes, we can track the
extent to which there is evidence of further
homogenization or diversification in codes (for
example in terms of structure, issues and
wording).
Recommendations
An assessment of content is just one aspect of the
overall evaluation of a business code. Another
factor concerns the extent to which a code
demonstrates a company’s awareness of relevant
and topical issues, organizational dilemmas and
stakeholder expectations (Kaptein and Wempe,
1998). Judging individual codes merely based on
desk-research and just in terms of comprehen-
siveness is therefore not justified. Moreover, some
norms may be so self-evident – for instance the
prohibition on killing someone in the workplace
– that it need not be included in the code despite
the fact that it remains valid.
Another significant aspect is the process
through which the code is established and
institutionalized. A code is nothing, coding is
everything (Kaptein and Wempe, 1998). The
quality of individual business codes can there-
fore only be determined by conducting research
on these aspects as they manifest in practice.
We can, nevertheless, in random order, put
forward a number of general suggestions for
improving codes.
• Accountability: The impact and credibility of
a code can be enhanced by making a com-
mitment to stakeholders to periodically
account for implementation and compliance
with the code, for example in an annual
report (Van Tulder and Kolk, 2000). Only
4% of the analyzed codes address external
reporting.
• Feedback: A company can use a code as a
means to invite internal and external stake-
holders to share their ideas on improving
the code or even its implementation.
28 Muel Kaptein
Although many companies have institu-
tionalized and refer to an internal ethics
hotline (Kaptein, 2002), it is often unclear
to external stakeholders who they can turn
to. Only 5% of the examined codes indicate
that the company would appreciate external
stakeholders to report incidents and who
they can contact.
• A stimulating work environment: A key factor
in the proper implementation of a code is
that managers create a work environment
which enables and encourages employees to
observe the code (Benson, 1989; Tucker et
al., 1999). Few codes give a clear and con-
vincing account of its implementation
(25%) and the role fulfilled by management
(16%). Companies could therefore consider
placing more emphasis on the responsibility
the organization (and management in
particular) has in stimulating and creating
the conditions for employees to comply
with the code.
• Periodic update: If a code is to be a relevant
and meaningful document, it is not only its
implementation that should be attended to
in great detail; it should also be updated at
regular intervals (Ethics Resource Center,
1990). Some business codes have not been
modified in more than ten years, which
increases the likelihood that new issues will
not be attended to. It is therefore advisable
that companies consider stipulating
(maximum) intervals between updates in
their codes. If a company refrains from
doing so updates might repeatedly be post-
poned. Moreover, in the event that updates
do occur unexpectedly, it could create sus-
picion among stakeholders that something
must be (fundamentally) amiss to have
prompted adjustment of the code. Apart
from that, most companies (86%) make no
mention of the process through which the
code came into being.
• Clear status of the code: Most codes are
unclear about the status of the code, that
is, to what extent the codes express decla-
rations of intent or actual business practice.
It is often also unclear how the code relates
to other regulations within and beyond the
boundaries of the company. In 67% of the
codes it is not clarified whether the norms
and values subscribed to in the code are also
worked out in greater detail in separate
policy documents and regulations.
• Availability of the code: Through this research
project, first hand experience was gained
of how cumbersome it can be to obtain
company codes (in a few cases it took more
than four months and in another few it took
between twelve and fifteen telephone calls
before the document was sent by mail). It
also appeared that some companies regard
their code as confidential or classified
information. Apart from that, codes are
often unavailable via the intranet or in
English (despite the fact that these com-
panies maintain business relations in
English-speaking countries).
• Convincing message: Some codes are
abstractly formulated. In theory, an abstract
code could be as effective (or even more
effective) as a detailed code (Kaptein and
Wempe, 1998). In that case, it is important
that (even more of) an effort is made with
implementation (due to the demand it
places on employees to translate it to their
specific functions). Companies with abstract
codes should therefore examine how it can
be made clear to users and readers that
abstraction is not an admission of weakness
but rather a considered admission of
strength.
• Clear structure: As we have seen, there is
strong divergence among the codes in terms
of structure. The structure depends, among
other things, on the type of code the
company has in mind (for instance orga-
nizing it according to stakeholder group or
values). At the same time, some codes
display considerable lack of coherence and
issues appear to have been assembled at
random. Organizational values especially are
at times scattered in the text or mentioned
only in the introduction. The impact of
core values in particular, lies in their selec-
tion (Collins and Porras, 1994).
• Appropriate presentation: Despite the fact that
the content of and process through which
 Business Codes of Multinational Firms
codes are established are of chief impor-
tance, the appearance of codes also says
something about a company’s regard for its
code (White and Montgomery, 1980). A
glossy publication, for example, can
generate suspicion that the company is more
concerned about its appearance than its
content. On the other hand, taking care
with a code’s presentation and style reflects
a company’s regard for the code and, by
implication, the length of time it expects
the code to serve (from being of one-off use
to being a reference). The examined codes
vary from being presented in the form of a
few standard photocopies to full color text
and photos printed on quality paper.
• Unique identity: The strength of and com-
mitment to the code is largely reflected in
the extent to which the code is tailored to
the company’s unique circumstances
(Pemberton and Pendergraft, 1990). The
texts of the codes display strong similarities
particularly with regard to the natural
environment and rules of conduct with
respect to fraud and corruption. The
current growth of international codes
increases the likelihood that companies will
adopt these texts (almost) literally in their
codes. If external stakeholders and
employees are to regard the code seriously,
companies should avoid appearing to have
been led by one or more codes of other
companies or international organizations
without having thoroughly thought through
their position is on the issue at hand.
Finally, another important question is whether
some types of codes are more effective than
others (Schwartz, 2001). A general code that
appeals to employees’ sense of responsibility
could be more effective than a very detailed code
which can easily be interpreted as a vote of no
confidence (Treviñio et al., 1999). We may
likewise ask what a code actually says about the
factual situation. The current growth in sustain-
ability reporting (KPMG, 2002) could perhaps
serve as point of departure in formulating an
answer to this question. As yet, this study shows
that on paper, many companies have an eye for
29
the responsible treatment of stakeholders along
with the principles, values and norms that
ground sound conduct.
Acknowledgement
Thanks to the two referents for their very useful
comments on an earlier version of this paper.
Notes
1
An analysis of business codes unravels the norms
and values companies endorse and provides insight
into the extent to which companies actually share the
principles that have been developed in the academic
field of business ethics. An inventory of so-called
micro-norms is also in keeping with the call of
Donaldson and Dunfee (1999) to supplement their
Integrated Social Contracts Theory with empirical
research on the ethics of business.
2
In calculating the prevalence of code types, each
code was examined to establish whether it elaborates
on at least two specific responsibilities towards stake-
holders, values or rules of conduct. Codes were
treated for instance as values statements only if the
company named the values as such and clustered them
as such in the code. If only a few scattered values
appeared in the text, the codes were not treated as
values statements.
3
This factor was calculated by dividing the number
of times an item occurs by the total number of codes
of conduct instead of by the total number of business
codes as was done earlier. This percentage was then
divided by the percentage of this item of the total
number of codes as presented in Table VIII.
References
Ashridge Centre for Business and Society: 2000,
Business Responses to Human Rights (Hertforshire).
Benson, G.: 1989, ‘Codes of Ethics’, Journal of Business
Ethics 8, 305–319.
Brooks, J.: 1989, ‘Corporate Codes of Ethics’, Journal
of Business Ethics 8, 117–129.
Collins, J. C. and J. I. Porras: 1994, Built to Last:
Successful Habits of Visionary Companies (Century
Business, London).
Cressey, D. R. and C. A. Moore: 1983, ‘Managerial
30 Muel Kaptein
Values and Corporate Code of Ethics’, California
Management Review 25(4), 53–77.
Donaldson, T. and T. Dunfee: 1999, Ties that Bind:
A Social Contracts Approach to Business Ethics
(Harvard Business School Press, Boston).
Ethics Resource Center: 1980, Implementation and
Enforcement: Codes of Ethics in Corporations and
Associations (Opinion Research Corporation,
Princeton, NJ).
Ethics Resource Center: 1990, Creating a Workable
Company Code of Ethics (ERC, Washington DC).
Farrell, B. J. and D. M. Cobbin: 1996, ‘A Content
Analysis of Codes of Ethics in Australian
Enterprises’, Journal of Managerial Psychology 11(1),
37.
Farrell, B. and D. Cobbin: 1996, ‘Mainstreaming
Ethics in Australian Enterprises’, Journal of
Management Development 15(1), 37–50.
Gordon, K. and M. Miyake: 2001, ‘Business
Approaches to Combating Bribery: A Study of
Codes of Conduct’, Journal of Business Ethics 34,
161–174.
International Labor Organization: 1999, A Social
Conscience in the Global Market Place: Labor
Dimensions of Codes of Conduct, Social Labeling and
Investor Initiatives (ILO, Geneva).
Kaptein, M. and J. Wempe: 1998, ‘Twelve Gordian
Knots when Developing an Organizational Code
of Ethics’, Journal of Business Ethics 17, 853–869.
Kaptein, M. and J. Wempe: 2002, The Balanced
Company: A Theory of Corporate Integrity (Oxford
University Press, Oxford).
Kaptein, M.: 2002. ‘Guidelines for the Development
of an Ethics Safety Net’, Journal of Business Ethics
41, 217–234.
Kolk, A. and R. Van Tulder: 2002a, ‘Child Labor and
Multinational Conduct: A Comparison of
International Business and Stakeholder Codes’,
Journal of Business Ethics 36, 291–301.
Kolk, A. and R. Van Tulder: 2002b, ‘The
Effectiveness of Self-regulation: Corporate Codes
of Conduct and Child Labor’, European
Management Journal 20, 260–270.
KPMG Belgium: 2002, Business Codes in Belgium
2002 (KPMG, Brussels).
KPMG Canada: 2002, Ethics and Corporate Social
Responsibility Survey 2002: Ethical leadership (KPMG
Forensic, Toronto).
KPMG Germany and Universität Erlangen-Nürnberg:
1999, Unternehmensleitbilder in Deutschen
Unternehmen (KPMG, Frankfurt).
KPMG India: 2002, India Fraud Survey Report 2002
(KPMG, Forensic).
KPMG International and University of Amsterdam:
2002, KPMG International Survey of Corporate
Sustainability Reporting 2002 (KPMG, De Meern).
KPMG South Africa: 2002, Southern Africa Fraud
Survey 2002 (KPMG Forensic).
Langlois, C. C. and B. B. Schlegelmilch: 1990, ‘Do
Corporate Codes of Ethics Reflect National
Character? Evidence from Europe and the United
States’, Journal of International Business Studies 4,
519–539.
Lefebvre, M. and J. B. Singh: 1992, ‘The Content of
Focus of Canadian Corporate Code of Ethics’,
Journal of Business Ethics 11, 799–808.
London Business School and Arthur Andersen: 2000,
Ethical Concerns and Reputation Risk Management:
A Study of Leading U.K. Companies (London).
Mathews, M. C.: 1987. ‘Codes of Ethics:
Organizational Behavior and Misbehavior’, Research
in Corporate Social Performance and Policy: Empirical
Studies of Business Ethics and Values 9, 107–130.
Nakano, C.: 1997, ‘A Survey Study on Japanese
Managers’ Views of Business Ethics’, Journal of
Business Ethics 16, 1737–1751.
McIntosh, M., R. Thomas, D. Leipziger and G.
Coleman: 2002, Living Corporate Citizenship:
Strategic Routes to Socially Responsible Business
(Prentice Hall/Financial Times, London).
Pemberton, J. M. and L. O. Pendergraft: 1990,
‘Toward a Code of Ethics: Social Relevance and
the Professionalization of Records Management’,
ARMA Quarterly 24, 2–15.
Petrick, J. A. and J. F. Quinn: 1997, Management
Ethics: Integrity at Work (Sage, Thousands Oaks).
Raiborn, C. A. and D. Payne: 1990, ‘Corporate
Codes of Conduct: A Collective Conscience and
Continuum’, Journal of Business Ethics 9, 879–889.
Robin, D., M. Giallourakis, F. David and T. Moritz:
1989, ‘A Different Look at Codes of Ethics’,
Business Horizons, 66–73.
Schwartz, M. S.: 2001, ‘The Nature of the
Relationship between Corporate Codes of Ethics
and Behavior’, Journal of Business Ethics 32,
247–262.
Schwartz, M. S.: 2002, ‘A Code of Ethics for
Corporate Code of Ethics’, Journal of Business Ethics
41, 27–43.
Sims, R. R. and J. Brinkmann: 2003, ‘Enron Ethics
(Or: Culture Matters More than Codes)’, Journal
of Business Ethics 45, 243–256.
Treviño, L. K., G. R. Weaver, D. G. Gibson and
B. L. Toffler: 1999, ‘Managing Ethics and Legal
Compliance: What Works and What Hurts?’,
California Management Review 41(2), 131–151.
 Business Codes of Multinational Firms
Treviño, L. K., L. P. Hartman and M. Brown: 2000,
‘Moral Person and Moral Manager: How
Executives Develop a Reputation for Ethical
Leadership’, California Management Review 42(4),
128–142.
Tucker, L. R., V. Stathakopolous, C. H. Patti, ‘A
Multidimensional Assessment of Ethics Codes: The
Professional Business Association Perspective’,
Journal of Business Ethics 19, 287–300.
Van Tulder, R. and A. Kolk: 2000, ‘How
Multinationality affects Ethics: Codes of Conduct
in the Sporting Goods Industry’, Journal of
International Business Studies 32(2), 267–283.
Van Tulder, R., D. Berghe and A. Muller: 2001,
Erasmus (S)Coreboard of Core Companies: The World’s
Largest Firms and Internationalization (Rotterdam
School of Management, Rotterdam).
VNO-NCW, KPMG and Ethicon: 1991, 1999, 2003,
The Business Code (The Hague).
Waddock, S. A., C. Bodwell and S. B. Graves: 2002,
‘Responsibility: The New Business Imperative’,
31
The Academy of Management Executive 16(2),
132–147.
Weaver, G. R., L. K. Treviño and P. L. Cochran:
1999a, ‘Integrated and Decoupled Corporate
Social Performance: Manager Commitments,
External Pressures, and Corporate Ethics Practices’,
Academy of Management Journal 42(5), 539–552.
Weaver, G. R., L. K. Treviño and P. L. Cochran:
1999b, ‘Corporate Ethics Practices in the Mid-
1990s: An Empirical Study of Fortune 1000’,
Journal of Business Ethics 18, 283–294.
White, B. J. and B. R. Montgomery: 1980,
‘Corporate Codes of Conduct’, California
Management Review 23(2), 80–87.
Department Business-Society Management,
Erasmus University Rotterdam,
P.O. Box 1738,
3000 DR Rotterdam,
The Netherlands,
E-mail: Kaptein.muel@kpmg.nl