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A Cross Cultural Comparison of the Contents of Codes of Ethics: USA, Canada and Australia

Greg Wood

ABSTRACT. This paper examines the contents of the codes of ethics of 83 of the top 500 companies operating in the private sector in Australia in an attempt to discover whether there are national characteristics that differentiate the codes used by companies operating in Australia from codes used by companies operating in the American and Canadian systems. The studies that were used as a comparison were Mathews (1987) for the United States of America and Lefebvre and Singh (1992) for Canada. The major conclusion is that, whilst Australian codes do have some characteristics that differentiate them from the other two groups, it appears that companies in all three cultures are driven by the same motives to develop codes.

Introduction Codes of ethics are one of the tangible ways to examine whether organisations have recognised the need for ethical behaviour and have established a commitment to that need. The corporation should make a conscious decision to pursue the goal of having a corporate code of ethics. The document is one that needs to be constructed based upon the values in business
Greg Wood is a Senior Lecturer in Management and Marketing at Deakin University, Warrnambool, Australia. He holds a Dip.T., B.Ed. (Sturt CAE), M.Ed. (Deakin) and has just submitted his PhD in Management Ethics for examination. He is also a Fellow of the Australian Marketing Institute, a Member of the Australian Institute of Management and a Certified Practising Marketer. As well as academic experience he spent from 1981-1990 working for Shell Australia or its affiliates. In 1987 he was the inaugural Shell Regional Manager, Northern Pacific, based on Guam, USA.

that each organisation wishes to enunciate to its employees and the public at large (Weber, 1981) and it should be framed in respect to the particular business environment in which the organisation finds itself (Murphy, 1989). This business environment includes a consideration of not only the industry in which it exists, but the culture of the country or countries in which it conducts its business. One should be able to investigate the content of the codes to examine whether these contents reflect the culture of the society in which the organisations exist. The purpose of this research was to examine the content of codes of ethics of companies operating within Australia to see if there were national characteristics evident amongst them that may have differentiated them from codes that exist in other, similar cultures. 1 The intent of reading each code was to compare the contents, specifically to that of previous studies in America by Mathews (1987) and in Canada by Lefebvre and Singh (1992).

Methodology A questionnaire was sent to the top 500 companies operating in the private sector within Australia. The basis of selection was the size in $Australian of company turnover (De Biasi F. and McBride B., 1993). The aim of the questionnaire was to obtain from the participants a copy of their code of ethics and for them to answer a set of up to forty-six questions concerning the methods used by their organisations to inculcate an ethical ethos into the daily operating activities of the organisation and its employees. The package sent to the companies contained

Journal of Business Ethics 25: 287–298, 2000. © 2000 Kluwer Academic Publishers. Printed in the Netherlands.


Greg Wood They had a response rate of 48.9%. The focus of the survey was upon the content of the 75 codes of ethics that were forwarded to them. They did not, as in the case of Mathews (1987), attempt to link the content of the codes with any other variable. Mathews (1987) listed ten categories with sixty-four smaller divisions from which the analysis was made. The analysis criteria were based upon the previous work of Cressey and Moore (1983). The frequency of mention of the items within the codes was analysed. The amount of space devoted to each item was also analysed. Lefebvre and Singh (1992) used the same method of analysis as Mathews (1987). Lefebvre and Singh used seven categories based on Mathews’ original work. However, the number of smaller divisions proposed by Lefebvre and Singh was sixty-one. Whilst removing some smaller divisions from Mathews’ Federal Agencies/ Commissions referred to, Lefebvre and Singh also added more divisions in Conduct on Behalf of the Firm, and in General Information. This study used the Lefebvre and Singh framework for ease of comparison across the three cultural groups. The Australian survey departed from the methodology of the other two analyses. The frequency of mention was maintained within each item but the amount of space or implied relative importance of each item was not used. The amount of space devoted to an item within the code may not necessarily correlate with the importance that the company attaches to it. The space devoted to it could well be a feature of the difficulty in expressing the concept. Some of the most central concepts can be expressed easily because we understand the importance of the concept itself and it is integral to our culture. Thus, the figures for the other two surveys per item were then aggregated and compared against the Australian figures for frequency of mention.

a covering letter, the questionnaire and an overview of the researcher’s background in both business and academia. The package was sent to the Public Relations Manager in each organisation rather than the CEO. This was done in the hope that, as Public Relations professionals are focussed on providing information in a positive light in their every day jobs on behalf of the organisation then, they may have been more dedicated to the task than other company functionaries. Each respondent was assured of complete anonymity as the results were to be aggregated. A month after the expiration of the return date of the original survey a second complete package was sent to the addressees that had not responded. The survey achieved a response rate of 68%. Of the three hundred and forty companies that replied, fifty-three refused to participate for a variety of reasons that mainly focussed upon lack of time and company policy not to participate. Added to this figure were the responses of eight companies that believed that they had sent in a code of ethics but upon examination the document was not one that could fit any concept of a code. The responses of the remaining two hundred and seventy-nine companies led to the analysis of the content of the eighty-three codes that were received.

The studies against which the comparison was made The study by Mathews (1987) looked at 485 manufacturing firms in the United States of America in an attempt to examine the impact of a code of ethics on the aspect of corporate crime related to illegal behaviour that directly affected consumers and the general public. Mathews had a response rate of 71% to the survey document with 202 useable codes available for analysis. Mathew’s principal finding was that codes of conduct and corporate violations did not have a discernible relationship. Codes of conduct were also not viewed by Mathews as being able to enforce self-regulation by the corporation. Lefebvre and Singh (1992) surveyed 461 companies from the Financial Post 500 in Canada.

Analysis of the results The results are compiled into eight tables that segment the various major areas. All figures stated are percentage figures of actual mention of the

A Cross Cultural Comparison of the Contents of Codes of Ethics item in the codes of the companies that responded.


Conduct on behalf of the firm The first area of consideration is that of the “Conduct on Behalf of the Firm”. This area is concerned with the behaviour that is exhibited by employees when representing the organisation. It looks at the dealings that employees have with governments, competitors, customers, suppliers, the community and fellow employees in terms of health and safety. The US codes focus predominantly on the issues involved with governments, both internal and foreign, competition, and political contributions. These areas are ones that form the basis of American business. The US system is predicated on maintaining competition. Any actions that diminish the level of competition fall under the auspices of Anti-Trust and Competition laws. There also is a sharper focus upon the dealings with governments.

The focus in America (86.6%) and Canada (58.7%) on “Relations with the home government” is much greater than companies operating within Australia (24.1%). There is an influence from the United States presence here, in that Australian subsidiaries of US corporations often still maintain this home government focus. It highlights that the interrelationship between government and business in the American system, in particular, is one that is more pervasive than in the Australian context. The US focus on foreign governments (73.3%), which is far in excess of the Australian (10.8%) and Canadian positions (22.7%), is indicative of the fact that many US enterprises are now global corporations. The US for many years has taken its business to the world whilst in the Australian context the focus has only recently been deemed to be outside of Australia. For many years Australia ran protectionist policies encompassing tariffs and quotas that enabled us to focus inwards rather than outwards. Australian codes, in respect to dealing with foreign governments, reflect a different focus to the

TABLE I A cross cultural comparison of code content (a) Research study: Country: Year: Conduct on behalf of the firm 01. 02. 03. 04. 05. 06. 07. 08. 09. 10. 11. 12. Relations with home gov’t Relations with customers/suppliers Relations with employees-health, safety Relations with competitors Relations with foreign gov’ts Relations with investors Civic and Community affairs Relations with consumers Environmental affairs Product safety Product quality Payments or political contributions to gov’ts or gov’t officials or employees 13. Acceptance of bribes, kickbacks, gifts/entertainment 14. Giving of bribes, kickbacks, gifts/entertainment 86.6 86.1 37.1 58.0 73.3 41.1 24.8 23.3 12.9 09.0 21.3 84.7 N/A N/A 58.7 77.4 48.0 29.3 22.7 32.0 33.3 33.3 21.3 12.0 24.0 62.7 82.7 66.7 24.1 86.7 53.0 33.7 10.8 30.1 45.8 09.6 37.3 14.5 34.9 41.0 68.0 53.0 M USA 1987 L&S CAN 1992 Wood AUS


Greg Wood light, more than the American and Canadian codes, both product safety and employee health and safety. It would appear that in the area of “Conduct on Behalf of the Firm” that Australian companies are more focussed than their Canadian or American counterparts on the social issues of environment, community, product performance and the well being of workers. This last point is considered by Benson (1989, p. 309) when he says,
It seems quite likely that those firms that do enunciate their obligations to the employee in their codes of ethics are more likely to inspire faith on the part of the employees than those that neglect this aspect of corporate responsibility.

Americans. This may be, as stated, because Australian corporations have not had a foreign focus for as long as the Americans. However, it just may well be that the perception of Australian corporations of the need to involve ourselves with governments, both within the home country and thus extended into one’s international dealings, is perceived differently and is thus, culturally specific. Companies operating in Australia (9.6%) in the area of “Relations with consumers” appear to not focus upon this issue. The US (23.3%) and Canadian (33.3%) involvement with the concept of consumers is much more pronounced than the Australian situation. The contention here is that Australian companies are not any less considerate of their relations with consumers but that the word, consumer, is one that is not used in the codes. Australian based organisations, it would appear, tend not to differentiate between customers and consumers. Canadian companies (82.7%) are more focussed upon bribes and kickbacks than in Australia (68%). One point of interest here is that in both Australian and Canadian codes, employees are advised not to take bribes in greater percentages than they are advised not to give them. The Australian codes highlight the areas of community involvement, environmental issues and product quality. The Australian codes high-

This idea highlights the benefit of including commitments to employees because the employees may see the worth of the code in a much more personal and relevant light.

Conduct against the firm The focus in this category is to endeavour to highlight those areas of action that could damage the company itself. The interesting point is that the Australian situation, in this area, places Australian companies between the American and Canadian positions for numbers 16, 17, 18, 19, and 21.

TABLE II A cross cultural comparison of code content (b) Research study: Country: Year: Conduct against the firm 15. 16. 17. 18. 19. 20. 21. 22. Conflict of interest Divulging trade secrets/proprietary information Insider trading information Personal character matters Other conduct against the firm Integrity of books and records Legal responsibility Ethical responsibility 75.3 45.1 43.1 06.4 10.4 75.3 90.6 88.1 93.3 81.3 720. 50.7 520. 82.7 320. 70.7 72.3 67.5 56.6 20.5 30.1 57.8 79.5 62.7 M USA 1987 L&S CAN 1992 Wood AUS

A Cross Cultural Comparison of the Contents of Codes of Ethics Australian companies seem comparatively to take the middle ground in this area.


Testing the relationship between “conduct against the firm” vs “conduct on behalf of the firm” Lefebvre and Singh (1992) suggest that Canadian companies flag “Conduct Against the Firm” more frequently than “Conduct on Behalf of the Firm”. Mathews (1987) also found that with the American codes studied that the focus was also more internal rather than external. This idea in respect to American codes is also supported by Chatov (1980), Cressey and Moore (1983) and David (1988). One could speculate that this focus shows a desire to use codes as inward regulatory documents rather than outwardly focussed documents. Chatov (1980, p. 29) encapsulates this ideal well when he contends that,
Most corporate attention is given to areas with a potential for dramatic impact on the corporation. That the corporation will be a transgressor or a victim is of most concern.

An attempt was made to try and quantify this contention. By adding up the frequencies of mention for each point in codes across the US, Canadian and Australian samples for “Conduct on Behalf of the Firm” and “Conduct Against the Firm” one could compare them. Table III shows that “Conduct Against the Firm” is mentioned in codes much more frequently on average than “Conduct on Behalf of the Firm”. The calculation was based upon adding the frequency of mention for each item in the two categories and then dividing by the number of items in each

category. The figures which were arrived at were compared. In the US codes the increase on average is 16.7% yet in the Canadian codes (54.9%) and the Australian codes (44.2%) the concentration on “Conduct Against the Firm” is decidedly higher per point mentioned as compared to “Conduct on Behalf of the Firm”. These figures would support the contention of the trend amongst corporations in the 3 societies to focus inwards rather than outwards. Hence, it could be suggested that the code of ethics is a document established to protect the organisation first and its publics second. This obviously raises the issue of whether such intent is ethically motivated based on the welfare of stakeholders or is motivated by mercenary values of self-preservation of the organisation. One can not lay blame with organisations for wanting to ensure survival, as it is a basic human instinct, but it would appear that companies may mask the true intent of their codes. They may use the facade that the codes are there to protect all stakeholders when in actual fact, the focus is selfprotection and preservation. Many codes are not designed as codes of ethics or codes of conduct but as codes of company continuance.

Laws cited This category examines the frequency of mention in each code of the particular laws of each country. The Competition laws are the ones most mentioned in US (33.2%), Canadian (44%) and Australian (32.5%) codes. Australian codes

TABLE III A cross cultural comparison of code content (c) Research study: Country: Year: a) Conduct on behalf of the firm b) Conduct against the firm b)/a) M USA 1987 46.5%0 54.29% 1.167 L&S CAN 1992 43.15% 66.84% 1.549 38.75% 55.88% 1.442 Wood AUS


Greg Wood
TABLE IV A cross cultural comparison of code content (d)

Research study: Country: Year: Laws cited (in references to) 23. 24. 25. 26. 27. 28. 29. 30. 31. Competition act/Anti-trust/TPA* Securities Environment Food and drug Product safety & quality Worker health/safety Bribes or payments to gov’ts or officials False advertising Other laws

M USA 1987

L&S CAN 1992

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33.2 14.4 00.5 00.5 010. 04.5 18.8 08.4 080.

440. 240. 09.3 000. 000. 09.3 14.7 02.7 120.

32.5 15.7 13.3 01.2 060. 15.7 14.5 02.4 43.4

* Australian equivalent: TPA = Trade Practices Act.

contain more mentions than US or Canadian codes in the areas of “Environmental Laws” and “Worker Health and Safety Laws”. This observation fits with the earlier point in Table I that noted that Australian codes mentioned these areas more than the US and Canadian codes. The Australian codes (43.4%) in respect to “Other laws” are far in excess of the US (8%) and Canadian (12%) situations. The major law cited is that of Equal Employment Opportunity (EEO) involvement in respect to employment and harassment legislation. The mention of EEO in Australian codes is 48.2%. This could be seen to be a feature of the fact that 47% of these codes were established since 1991 (Wood,

1997). In Australia, there has been a concerted push and recognition of the need for EEO practices. It is a legal requirement of business in Australia. Obviously, it is an issue that companies feel needs to be at the forefront of the minds of employees.

Governmental agencies/commissions referred to Table V examines the incidence of where codes refer to specific Government agencies. These figures show that basically there is a minimal mention of these Government agencies in the Australian and Canadian codes.

TABLE V A cross cultural comparison of code content (e) Research study: Country: Year: Governmental agencies/commissions referred to 32. Competition tribunal/TPA 33. Other agencies N/A N/A 1.3 0.0 0.0 7.2 M USA 1987 L&S CAN 1992 Wood AUS

A Cross Cultural Comparison of the Contents of Codes of Ethics The six companies (7.2%) in Australia that mentioned other agencies were all organisations with an American parent.


Types of compliance/enforcement procedures Table VI examines the types of compliance and enforcement procedures that are stated in the codes. The areas mentioned can be grouped into internal oversight, internal personal integrity, and external. Each area focuses on a different perspective of the same issue. Internal oversight

measures are those individuals and committees inside the company that are charged by the organisation with maintaining a vigilance concerning the behaviour of other employees. Internal personal integrity matters are concerned with individuals or committees within the organisation to whom individuals may go if they are concerned with ethical matters that relate to their own actions or those of others within the organisation. The external group is comprised of outside individuals or agencies that are also used to monitor the ethical performance, and in some cases legal performance, of employees.

TABLE VI A cross cultural comparison of code content (f) Research study: Country: Year: Types of compliance/enforcement procedures Internal – oversight 34. 35. 36. 37. 38. 39. 40. Supervisor surveillance Internal watchdog committee Internal audits Read and understand affidavit Routine financial budgetary review Legal department review Other oversight procedures 41.1 18.3 22.9 060. 02.5 36.1 25.8 45.3 09.3 34.7 45.3 01.3 09.3 18.7 21.7 08.4 120. 20.5 01.2 07.2 09.6 M USA 1987 L&S CAN 1992 Wood AUS

Internal – personal integrity (For questions repolicy or reporting misconduct of self or others to:) 41. 42. 43. 44. 45. 46. 47. Supervisor Internal watchdog committee Corporation’s legal counsel Other (in firm) Compliance affidavits Employee integrity Senior management role models 34.1 12.4 600. 530. 44.6 49.5 04.5 69.3 000. 440. 46.7 34.7 440. 6.7 49.4 060. 32.5 25.3 120. 43.4 8.4

External 48. 49. 50. 51. Independent auditors Law enforcement Other external Codes mentioning enforcement or compliance proced. 17.3 01.0 00.5 79.7 13.3 01.3 01.3 70.7 01.2 000. 03.6 51.8


Greg Wood the United States (60%) and companies operating in Australia (32.5%). Of the companies operating in Australia, who mentioned the use of the corporation’s legal counsel, 78% were companies with a US parent. Only three Australian owned companies used this approach. Employee integrity is basically similar in all three code groups and is integral to the process. This area of employee integrity is basically a nom de plume for the expectation of companies that individuals will engage in whistleblowing. The ways in which this process is framed in Australian codes is that one should inform one’s supervisors of either one’s concerns with one’s own actions or with the actions of other members of the organisation. Hence, individual employees become an internal oversight mechanism. The request is made of the strength of character of employees to question that which they see as being of concern. Not only should they question these situations but they are requested, as a part of their corporate duty, to pursue any concerns or irregularities with more senior authority figures within the organisation. Companies operating in Australia (8.4%) do tend to use senior managers as role models more than US (4.5%) and Canadian (6.7%) organisations. The use of external monitors for unethical behaviour appears to be an anathema to Australian companies. Only 1 company mentioned the use of an independent auditor. Also Australian codes (51.8%) mention the fact of having enforcement and or compliance procedures in comparison with their US (79.7%) or Canadian (70.7%) counterparts. Companies operating within Australia seem to focus less on the use of external measures than either American or Canadian organisations. Lefebvre and Singh (1992) contend that companies do not use external agencies to monitor company practices because of the possibility of the external organisation revealing to the general public the infraction. Hence, internal surveillance and vigilance is preferable to external monitoring because of the potential downside of poor publicity in case one transgresses and it becomes public knowledge.

Australian companies have less internal oversight provisions formally stated in their codes than American and Canadian organisations. Supervisor surveillance (21.7%) is the major area of internal oversight of companies operating in Australia followed closely by read and understand affidavit (20.5%). Supervisor surveillance in Australia is much lower than the US (41.1%) and Canadian (45.3%) incidences. Australian companies also mention in their codes, at a far lesser rate than the Americans or the Canadians, the procedures of internal watchdog committee, internal audits, legal department review and other oversight procedures. Australian codes appear to have less formal mechanisms for the monitoring of staff than the US and Canadian organisations. One could speculate that this phenomenon could be linked with the original supposition that Australian codes are less legalistic and more social than the other two sets of codes. Therefore, this social focus may also translate into a reduced rate of enforcement watchdogs due to a social belief in trusting individuals. Perhaps it also is a manifestation of the “don’t dob on your mates” mentality in Australia. This concept revolves around maintaining the unspoken code of the group which is firmly entrenched in the cultural more not to inform on friends and/or colleagues. When an employee within an Australian organisation needs to confront the possibility of their own unethical behaviour, or that of others, then nearly 50% of companies nominate the supervisor as the person to whom inquiries should be directed. This line of reporting can be a problem because often it is the supervisor who is a part of the problem and not the solution (Baumhart, 1961; Brenner and Molander, 1977). Companies operating within Australia (12%) do not use compliance affidavits to the same extent as American (44.6%) and Canadian (34.7%) organisations. By using compliance affidavits one can ensure that employees must at least take some time to assess their performance in the area of ethics. This idea has merit in that it forces individuals to face their own performance over a given period of time. Also one can see again the marked difference between the involvement of legal counsel between companies operating in

A Cross Cultural Comparison of the Contents of Codes of Ethics Penalties for illegal behaviour This category examines the mechanisms that companies foreshadow as penalties for those individuals who breach the intent of the code. The internal penalties applied by the organisations of the three countries are of similar frequencies in most areas. Companies operating in Australia however, do not appear to favour demotion with only one company mentioning it as an option. This could well be a cultural situation. Australian companies tend not to demote, but to release the employee, and, in some cases, source outplacement services for that individual. Demotion, by its very nature, is debilitating to the reputation and, one assumes, the motivation of the individual concerned. It can also have a negative effect on other employees. If the breach is sufficient to warrant demotion then the person concerned would find it potentially difficult to obtain the trust of new subordinates or to regain the confidence of peers and supervisors. Hence, the individual and the organisation are in a no win situation. The concept of a fine for individuals is one that is not seriously entertained in the Australian context. As in demotion, only one company


considered a fine as an option. Again, this is a reflection of the Australian culture. It is a concept that is neither readily accepted by Australians nor practised in Australian business. The use of “Other internal penalty” is of interest. Most companies in the Australian context, that consider this issue, discuss the ultimate penalties of “Dismissal” and or “Legal prosecution” in some detail. In concert with this discussion is invariably the open ended statement that allows the implementation of a continuum approach to sanctions, in respect to breaches of the codes. Usually the companies have an overriding statement that ties the penalty to the degree of perceived infraction. Hence, it makes the code less prescriptive and introduces flexibility. It provides the ability to judge each situation on its merits. Companies operating in Australia (24.1%) are extremely similar to the United States (26.2%) companies in respect to pursuing legal prosecution of wrongdoing against the company. The Canadian figure of 14.7% is lower.

TABLE VII A cross cultural comparison of code content (g) Research study: Country: Year: Penalties for illegal cehaviour Internal 52. 53. 54. 55. 56. Reprimand Fine Demotion Dismissal/firing Other internal penalty 060. 000. 070. 37.7 25.8 080. 02.7 05.3 46.7 26.7 09.6 01.2 01.2 39.8 34.9 M USA 1987 L&S CAN 1992 Wood AUS

External 57. Legal prosecution 58. Other external penalty 26.2 01.5 14.7 040. 24.1 03.6

296 General information

Greg Wood the employees of the organisation. This is an excellent move because it not only personalises the code for the workers but it highlights the commitment of senior staff to pragmatic action rather than platitudes (Serpa, 1985; Stoner, 1989; Gellerman, 1989; Sims, 1991; Laczniak and Murphy, 1991). The major focus mentioned in the codes of companies operating within Australia was an international focus. A home country focus was only stated by six companies. This international focus could be as a direct result of the fact that the group, who had codes and mentioned other than home country, were often Australian subsidiaries of international organisations or select Australian companies that had expanded internationally. Each group obviously realised the importance of focussing on the international dimensions of their business practices. The researcher also added one other category to the original categories of Lefebvre and Singh (1992). The extra item was Equal Employment Opportunity. The reason for adding this category was related to the frequency of this topic that kept arising when one read the codes. It was mentioned by just under 50% of companies. Therefore, the author believed that this significant factor could not be ignored. Equal

The information in this section examines general information that explores a number of dissimilar concepts that whilst not directly related can provide more insights in to the intent of the codes of ethics that are being analysed. A significant point in this final section is that companies that operate in Australia (62.7%) are more likely to have in their code the insistence that one protects the corporation’s good reputation than American codes (46.1%) and Canadian codes (50.7%). The protection of reputation is viewed as extremely important in the Australian context. The only reason that can be offered is purely speculative. The fact that companies operating in Australia tend to focus more upon the social issues in respect to their actions may lead them to place a higher value than others upon the social interaction of themselves with the community. Hence, a lack of protection of company reputation leads to a tarnished public image and the resultant impact on the perception of the corporation in the market place. Just on 50% of companies operating in Australia included, with their codes, a letter from the Chief Executive Officer or another senior functionary recommending the code to

TABLE VIII A cross cultural comparison of code content (h) Research study: Country: Year: General information 59. Need to maintain corporation’s good reputation 60. Letter/introductory remarks from the president/CEO/chairperson of the board 61. Code specific to which country i.e., Home Country World/general Others Added: 62. EEO 48.2 46.1 N/A 50.7 42.7 62.7 50.6 M USA 1987 L&S CAN 1992 Wood AUS

50.7 37.3 120.

07.2 43.4 N/A

A Cross Cultural Comparison of the Contents of Codes of Ethics Employment Opportunity would fit into the section on “Conduct On Behalf of the Firm”.


Conclusion Companies operating within the private sector of Australian business have developed codes that are not distinctly Australian when compared to American and Canadian codes but which have elements that differentiate them in some matters. Australian codes are not dramatically different in construction and content. They do tend to focus upon a more social view of corporate relations. This social focus could well be societal based, but it could also be in some part due to the fact that the studies against which they were compared were from 1987 and 1992 respectively. The difference may just reflect a social progression and evolution in values over those periods of time. The Australian codes are profoundly less reliant on internal and external watchdogs and the use of the organisation’s legal representatives for guidance. This difference, one contends, is due to the different role of litigation in the business culture of the respective countries. American business, through its raft of Competition, Anti-Trust and Foreign Corrupt Practice acts, appears to be more heavily regulated than Australian business. The reliance on litigation in the United States is not something that is practised as frequently in Australia. Whilst Australian business is governed by competition laws they are not as pervasive in the culture as the same laws appear to be in the United States of America. It is a positive outcome that the executives of companies operating within Australia tend to take a proprietary interest in the codes, in that they commend the contents to the company’s employees. This is an excellent development in that it highlights the commitment of the top management of the organisation to the ethical values that it wishes to portray in the market place. Codes of ethics used within Australia have been developed with an Australian focus in mind. However, the influence of US corporations is obvious. Many Australian organisations

are subsidiaries of US corporations and the codes that they use are consequently influenced by the parent company. Whilst culture plays a part in shaping the codes of the individual companies within each country, the overriding force and the paramount concern of organisations within the three cultures appears to be: the self preservation and protection of the organisation.


An analysis of Hofstede’s work (1980) and (1983), on cross cultural differences based on his study of 160,000 workers in 60 countries of one multinational corporation, was made in Robbins et al. (1994). Australia was compared with like countries on Hofstede’s 4 variables and the USA and Canada had remarkable similarities to Australia on all variables. Due to the passage of time and the influence on Australia from North America since the early eighties, via increased telecommunications and company involvement in Australia, one could expect these scores to become more convergent rather than divergent.

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Bowater School of Management and Marketing, Deakin University, Po Box 423, Warrnambool, Victoria, 3280, Australia e-mail: