J Bus Ethics (2019) 157:797–811
DOI 10.1007/s10551-017-3681-5
REVIEW PAPER
Compliance Through Company Culture and Values:
An International Study Based on the Example of Corruption
Prevention
Kai D. Bussmann1 • Anja Niemeczek2
Received: 30 November 2016 / Accepted: 19 August 2017 / Published online: 2 September 2017
 Springer Science+Business Media B.V. 2017
Abstract The aim of this Web-based survey of 15 German
companies with an international profile was to identify
which higher-level values serve as a basis for a company
culture that promotes integrity and can thereby also be used
to promote crime prevention. Results on about 2000
managers in German parent companies and almost 600
managers in Central and North European branch offices
show that a major preventive role can be assigned to a
company culture that promotes integrity. This requires a
‘tone from the top’, ‘ethical leadership’ from the direct
superior, and a general set of values that can be encouraged
through training courses. Moreover, employees have to
perceive these values as promoting their careers. The sur-
vey reveals that the companies in this study have basically
succeeded in establishing their system of values in their
Central and North European as well as their Asian branch
offices. Moreover, it shows that the main values preventing
crime on the management level are trustworthiness and
consistency. Open communication is an important value on
all levels of a company, and this is supplemented by
transparency, compliance with the rules, and a rejection of
behaving in one’s own interest. It is concluded that in spite
of regional differences, major international companies can
possibly make an important contribution to bringing about
& Kai D. Bussmann
kai.bussmann@jura.uni-halle.de
Anja Niemeczek
anja.niemeczek@gmail.com
1 cause of concern. In the sports club, in the family, and in
Law School, Martin-Luther-University Halle-Wittenberg,
Germany Universitätsplatz 6, 06108 Halle (Saale), Germany
2 that no longer applies for customers in a supermarket, in
Economy and Crime Research Center, Martin-Luther-
University Halle-Wittenberg, Germany Universitätsplatz 6,
06108 Halle (Saale), Germany
cultural change in regions with an affinity for corruption by
implementing a culture that promotes integrity in both their
company and their daily business.
Keywords Corporate culture
Corruption prevention

Ethical leadership
Integrity-promoting values
Tone from
the top
Preventing Crime Through Socialization
and Informal Social Control
In society, it is not law enforcement agencies that bear the
main burden of crime prevention, but above all socializa-
tion agencies such as the family, friends, school, and
neighbourhood (see Messner and Rosenfeld 2007). How-
ever, companies also serve as an important socialization
agency for preventing economic crime (Bussmann 2015).
This is becoming even more important because modern
moral research has ascertained that the validity of norms is
fragmenting (Nunner-Winkler 2004). Although offences
such as fraud are still rejected decisively in principle, norm
validity has become dependent on the specific situation and
compliance with norms has become negotiable. Norms are
applied differently in different situations and contexts, and
this is leading to their fragmentation. As a result of the
dynamic differentiation of life domains, citizens in a
modern society have become accustomed to ideas on val-
ues and morals no longer possessing absolute validity. As a
result, contradictions over values are frequently no longer a
the neighbourhood, norms can possess a degree of validity
dealings with banks or insurance companies, and especially
in relation to the state. This explains how otherwise
123
798
completely honest individuals are capable of committing
fraud or act corruptly in their daily business as managers:
they are acting in a different context. In addition, some
economic crimes are not self-evident. Unlike fraud and
theft, the harmful consequences of corruption, anti-com-
petitive arrangements, or insider trading are less immedi-
ately apparent (Bussmann 2015, p. 441).
However, crime prevention is not just based on the
internal agency of actors and on their shared norms and
values. It is also based on informal social control (Akers
2013; Brown et al. 2013). This does not just include all
conceivable social sanctions such as exclusion from shared
activities. It can already range from scornful looks, being
whispered about in one’s presence, frank criticism of
unwanted practices, up to public criticism within the
community. Studies on, for example, driving under the
influence of alcohol or tax evasion show that norm devia-
tions are influenced strongly by expectations regarding
informal sanctions (Grasmick et al. 1993; Worrall et al.
2014). Social pressure exerts a stronger sanctioning effect
than most penal sanctions, because of its permanence and
comprehensiveness (Nagin and Paternoster 1994).
Hence, there is a need for forms of informal social
control within companies that have to be supplemented by
a whistleblowing culture that will increase compliance
when necessary by communicating illegal activities to
superiors or other responsible persons such as the legal or
compliance department or an ombudsman (see Kölbel
2015, for an overview). Nonetheless, employees will desist
from whistleblowing if they personally have to fear social
sanctions from either their colleagues or the company
(Berry 2004; Rothschild and Miethe 1999). In contrast, if
they can trust that their information will be dealt with
appropriately, the threshold to whistleblowing may well be
lower. The whistleblowing procedure along with how such
information is processed is decisive for the readiness to
report incidents (Miceli and Near 2002; Rothwell and
Baldwin 2006).
Hence, an effective compliance management has to
possess more than just a legal structure. The concern is not
just with rules and their surveillance, but with establishing
a company culture that not only promotes integrity but also
integrates the willingness to engage in informal social
control. In all, it becomes clear that companies and, indeed,
organizations in general such as administrations have to
carry out a socialization task that other socialization
agencies such as the family and the community have not
been able to achieve sufficiently because they are embed-
ded in a different social and legal context.
123
K. D. Bussmann, A. Niemeczek
Company Culture and Values
Many companies have become fully aware of the need to
convey value management and to establish a company
culture through defined values. Nonetheless, the intended
crime-preventing effect does not occur per se through the
implementation of a compliance management. Its action-
guiding potential can develop only when it is embedded
within an ethical company culture (Valentine et al. 2014;
Verhezen 2010). It seems as if an initially more rule-ori-
ented, in other words, compliance-based culture in com-
panies is developing into one based more on values (Ferrell
et al. 2015). However, a company culture that promotes
integrity probably contains not only values that already
result from criminal norms such as the prohibition of cor-
ruption but also values that lead to an internalization of
penal law and encourage a shift towards such
internalization.
The first of these values that promotes integrity is
compliance with the rules itself when this becomes a value
in its own right. In addition, according to research on
behavioural integrity (Simons et al. 2015), it is necessary
for this compliance to be both consistent (see also de Bruin
2016, 27) and trustworthy, because contrary behaviour and
a poor reputation would, in turn, weaken the value of
compliance (see also Verhezen 2010, 189).
Moreover, research on the culture of integrity calls for
open communication and transparency (Verhezen 2010,
190ff.) so that non-compliant behaviour can be acknowl-
edged and discussed. From the perspective of criminology,
not speaking up is a breeding ground for economic crime
and particularly for corruption. As pointed out above, there
is a need for an informal social control that first becomes
possible through a speak-up company culture. Finally,
research on ethical climates has shown that an ego-centred
value culture generates an increase in counter-productive
work behaviour that also includes corruption (Eigenstetter
et al. 2007).
The starting point for any value management and the
development of a culture that promotes integrity always
lies with a company’s top management. This so-called
‘tone from the top’ is understood as company management
setting a good example and serving as a model for how to
deal with various types of economic crime. However, a
crucial aspect is its implementation on lower company
levels. Accordingly, positively perceived model behaviour
by the direct superior also exerts a positive influence on
employees (Brown et al. 2005; Kaptein 2011). This can be
described as ‘ethical leadership’ (Bhal and Dhadich 2011).
This model function particularly encourages acceptance of
the programme throughout a company (Weaver et al.
1999). However, the perceived fairness and justice of a
Compliance Through Company Culture and Values: An International Study Based on the Example…
direct superior’s leadership behaviour also contributes to
whether a company can succeed in creating an integrity-
promoting environment that will form a basis for the entire
business activity of its managers (Lind 1994; Tyler 1990;
Viswesvaran and Ones 2002).
This concept of a corporate culture that promotes
integrity can also be found in international guidelines. For
example, the International Standard 19600 for compliance
management systems emphasizes that all measures have to
be embedded within a compliance culture. It states:
The development of a compliance culture requires the
active, visible, consistent and sustained commitment
of the governing body, top management and man-
agement towards a common, published standard of
behaviour that is required throughout every area of
the organization (ISO 19600 section 7.3.2.3).
And it calls for this to be addressed with ‘a clear set of
published values’ and for a ‘management actively seen to
be implementing and abiding by the values’ (International
Standard ISO 19600 2014, p. 16). The guidelines for the
US Foreign Corrupt Practices Act (2004) and the UK
Bribery Act (2010) also emphasize the particular signifi-
cance of a culture based on ethical and corruption-aversive
values.
Value Management in a Globalized Economy
The value management of international companies is also
confronted with the typical regional values of foreign
cultures, and these influence the impact of a company’s
business ethics (e.g. Scholtens and Lammertjan 2007).
Moreover, specialized cross-cultural corruption studies
have shown that specific value orientations can be related
to the observed extent of corruptive structures in a country.
For example, there is a significant relation between the
collectivist value orientations of a country and its level of
corruption. Such values promote clientelism and the for-
mation and stabilization of exclusive corrupt networks
(House et al. 2004; Karstedt 2003). Societies shaped by
collectivist values tend to favour the in-group or own
organization. Corruption justifies itself in these networks,
because ideas on caring for one’s own collective make
them susceptible to corruption. Collectivist value orienta-
tions are assigned particularly to hierarchic-elitist nations
(Karstedt 2003). In the business context, managers in col-
lectivist cultures tend to make unethical decisions when
these seem advantageous for their own company or their
own extended family, and, as a result, they have an
uncritical view of such business practices in their company
(Sims 2009).
799
Moreover, intercultural comparisons reveal that a high
level of generalized trust in institutions, companies, and
persons is accompanied by a low level of corruption
(Tonoyan 2004; Uslaner 2005). In contrast, citizens and
companies with a low level of generalized trust compensate
this by building up exclusive networks in which they create
their own situation- and person-linked trust. For such net-
works, corruption is therefore almost a matter of course.
According to Paldam (2002), the lack of generalized trust
in post-Soviet states is one factor explaining their contin-
uously high level of corruption. In contrast, a low level of
corruption, as found, for example, in Scandinavian coun-
tries, can be attributed to a high level of generalized trust
(Björnskov and Paldam 2004). Karstedt (2003) relates both
a low level of generalized trust and a high level of inse-
curity to the conditions in hierarchic-elitist nations.
Further relations can be found to a strong power distance
in a society represented by a strongly hierarchic social
order, clearly differentiated social classes, and an authori-
tarian value system as frequently found in Latin American
and Asian countries (Graf Lambsdorff 2007; Hofstede and
Minkov 2013; La Porta et al. 1999). Particularly in coun-
tries in which hierarchic-elitist power structures go hand in
hand with an extremely unequal distribution of wealth, an
existing corruption problem will consolidate even further.
In addition, this leads to an increase in the social disposi-
tion to avoid uncertainty that makes the use of exclusive
(corrupt) networks continue to be attractive.
After controlling for prosperity indices such as the BIP,
this corruption-promoting influence can also be demon-
strated on the dimensions of power distance and avoidance
of uncertainty (Getz and Volkema 2001; Graf Lambsdorff
2007). Studies have shown significant relations between
power distance and the attitude of managers towards ethi-
cally questionable business practices (Christie et al. 2003).
Hence, research on corruption fundamentally confirms the
influence of nation-specific values on the level of corrup-
tion and the efficacy of various efforts to prevent corrup-
tion. This makes it necessary to assume that it will be a
challenging task to adapt a company culture and the values
conveyed by a mother company to a foreign branch or
subsidiary in a different culture.
Hypotheses
Although the following study addresses the example of
corruption compliance, the type of economic crime is
interchangeable. Drawing on a survey of managers of large
German companies, we first analyse what role they assign
to the company culture in their internal company crime
prevention.
123
800
As in the rest of society, a company also needs informal
social controls that, alongside socialization, bear the main
burden of crime prevention. Informal social control was
operationalized with case scenarios assessing the willing-
ness to talk to colleagues about their behaviour, to criticize
them, and to discuss the observation of compliance
infringements with them.
As a special form of informal social control, the
whistleblowing culture was also considered as a separate
variable. It addresses the willingness to turn, if necessary,
to the formal agencies of the company through, for
example, a whistleblowing system. Elements of a
whistleblowing culture include the motive for whistle-
blowing, fears about using the whistleblowing system, and
expectations regarding the consequences of its use.
These prior considerations lead to the first three
hypotheses:
Hypothesis 1 (H1) A company culture that promotes
integrity will have a direct negative effect on the willing-
ness to act corruptly.1
Hypothesis 2 (H2) A company culture that promotes
integrity will have a direct positive effect on informal
social control and increase the willingness to engage in it.
Hypothesis 3 (H3) A company culture that promotes
integrity will have a direct positive effect on the whistle-
blowing culture of a company.
Alongside the company culture, it is obviously neces-
sary to consider knowledge of the company guidelines and
rules. Compliance is hardly conceivable without norm-re-
lated and legal knowledge of the legal definitions of active
and passive corruption. Managers have to know where the
legal boundaries are located in their business practices.
Hypothesis 4 (H4) Knowledge of the norms has a direct
negative effect on the willingness to act corruptly.
There are various ways in which companies can exert a
positive influence on their company culture. Alongside the
‘tone from the top’ of company management and the direct
leadership behaviour of the immediate superior (ethical
leadership), values and behaviours can be taught in training
programmes. However, every company already possesses a
company culture, and this, in turn, will also influence the
development and implementation of any training pro-
gramme. It has to be assumed that the two will interact.
Hypothesis 5 (H5) There will be a positive interaction
between a company culture that promotes integrity and the
perceived quality of company training programmes.
1 assumed that this greater distance between cultural values
Respondents were given case reports documenting illegally making
gifts or accepting exclusive invitations in a competitive business
situation.
123
K. D. Bussmann, A. Niemeczek
Moreover, a company culture is not a construct that can
be measured directly. It is more of a latent variable formed
in different contexts. Such a culture is carried by the per-
ceived behaviour of top company management (the tone
from the top), the leadership of the direct superior (the
ethical leadership), and the general values regarding what
constitutes a successful career (the culture of success).
However, the perception of the tone from the top may be
regarded less positively in the subsidiaries abroad—par-
ticularly in Asian branch offices. This may be due to the
geographic distance and cultural differences.
Hypothesis 6 (H6) Concerning the tone from the top, the
parent company in Germany will show a higher mean value
compared to its branch offices and subsidiaries abroad.
Direct superiors function as a link between top company
management and the individual employee. For various
reasons, the group of direct superiors cannot be expected to
set the tone and communicate values to the same extent as
top management. For direct superiors, there are a great
number of multiplying factors, and a variety of these are
exposed to cultural influences. In addition, direct superiors
are closer to daily business, so that they are exposed to far
more pressure and have far more familiarity with deviant
practices. Moreover, they are probably exposed far more to
spillover effects from the specific regional culture.
Hypothesis 7 (H7) Ethical leadership from direct supe-
riors will show a lower mean value compared to the tone
from the top.
For companies, the question is not only which elements
such as tone from the top or ethical leadership belong to an
integrity-promoting company culture but also what values
they base this on. In line with the research reported above,
the following six values can be assigned a crime-prevent-
ing function: compliance, consistency, trustworthiness,
open communication, transparency, and non-egoism. The
survey in the German parent companies revealed that this
conglomerate of six values shapes a company culture that
promotes integrity.
Hence, it is necessary to examine whether these values
are also significant outside the parent companies. Particu-
larly in Asian branches, the company culture can be
expected to promote less integrity than in Germany and in
North or Central Europe. According to the aforementioned
corruption research, Asian countries are characterized by
fewer egalitarian values, a greater power distance, and less
generalized trust. Therefore, German companies can be
expected to face greater obstacles when trying to establish
their own value management in these countries. It can be
will make it harder to transfer a value-based compliance
programme to Asian branches and subsidiaries. The
Compliance Through Company Culture and Values: An International Study Based on the Example…
following hypotheses can be derived on the significance of
values:
Hypothesis 8 (H8) Consistency will show higher mean
values in German parent companies and in North and
Central Europe branch offices compared to Asian
subsidiaries.
Hypothesis 9 (H9) Trustworthiness will show higher
mean values in German parent companies and branches in
North and Central compared to Asian subsidiaries.
Hypothesis 10 (H10) The sample of German and North
and Central European managers will show higher mean
values on open communication than the samples of Asian
managers.
Hypothesis 11 (H11) The sample of German and North
and Central European managers will show higher mean
values on transparency than the samples of Asian
managers.
Hypothesis 12 (H12) Managers from Germany and
branches in North and Central Europe will reveal lower
mean values on egoism2 than managers from Asian bran-
ches and subsidiaries.
Hypothesis 13 (H13) Managers from German parent
companies and branches in North and Central Europe will
show higher mean values on compliance with rules than
Asian managers.
In line with the current state of research, the willingness
to act corruptly among German and European managers
will differ from that among managers in Asian branches
and subsidiaries.
Hypothesis 14 (H14) Asian managers will report higher
mean values on willingness to act corruptly than managers
from Germany and from North and Central Europe.
These hypotheses were tested with data from the
research project ‘Effectiveness of anti-corruption programs
on crime prevention’.3
Methods
The analyses draw on Web-based surveys of managers in
15 major German companies and their foreign branches
(see section on sampling below). Hypotheses 1–5 were
tested with complex structural equation modelling to
simultaneously analyse the cause–effect relations between
2
The value ‘‘egoism’’ was paraphrased in the questionnaire as
exploiting one’s authority and acting in one’s own interests, see
Table 3.
3
The study was funded by the German Research Foundation (DFG)
and ended 3/2016.
801
various factors of crime prevention. This statistical
approach integrates and extends both factor analysis and
multiple regression analysis (Kline 2011) in order to gain a
quantitative estimation of the interdependencies between
the manifest and latent variables in a model. The goal is to
deliver theoretically derived statements on relations
between various real-life phenomena in such formal terms
that their validity can be tested empirically (Schumacker
and Lomax 2015).
In the selected approach, the simultaneous estimation of
the model parameters was based on the empirical variance–
covariance matrix (Jöreskog 1970). The parameters of the
model were estimated with the maximum likelihood
method (Kline 2011). As the result of the model estimation,
standardized estimates were calculated in the form of path
coefficients that correspond within the structural model to
the beta weights in a regression analysis (Kline 2011). The
size of the beta weight is used to make statements on the
strength of the relation. In line with Chin (1998), path
coefficients contributing more than .20 are taken to be
significant.
Alongside a descriptive report on the response beha-
viour of the managers in the countries studied, a non-
parametric Mann–Whitney U test was used to analyse the
differences predicted in Hypotheses 6–13 between the
German parent companies and the branches and sub-
sidiaries in Asia (without China) and branches and sub-
sidiaries in North and Central Europe. This statistical test
assesses how far the specific groups differ in terms of their
central tendency. This is a distribution-free procedure that
tests for significant differences between group medians.
This procedure, which shows a degree of robustness
against outliers, was chosen because the data do not follow
a normal distribution.
Hypothesis 14 was examined with a Chi-square test for
homogeneity. This procedure can be used to test whether a
feature has an identical distribution in two independent
samples and is therefore used to determine whether the
willingness to act corruptly differs across the various
manager samples.
Samples
The study focuses on international companies and corpo-
rations that have already implemented an anti-corruption
programme and whose parent company is located in Ger-
many. The results of this study do not deliver a represen-
tative picture of German business, but show findings on
companies that possess a well-developed compliance
management that is, at the end of the day, an expression of
a differentiated value management.
In these companies, managers were surveyed regarding
their perceptions of, attitudes towards, and experiences
123
802
with compliance-relevant situations along with the values
conveyed in their company. This information was used to
determine relations between the willingness to act cor-
ruptly and various value dimensions. Managers were
informed about the survey in a letter from their company
inviting them to participate.4 Within each company, man-
agers were selected at random. Participation was voluntary
for all managers.
Managers from 15 large German companies,5 including
four corporations, were surveyed with the help of a Web-
based questionnaire.6 The companies sampled belong to
the automotive (n = 9), retail and consumer (n = 4), and
transport and logistics (n = 2) sectors. They have an
average of over 120,000 employees worldwide with the
smallest company having roughly 15,000 employees. A
large proportion of the managers (n = 1988) work in the
German parent company and are responsible for the Ger-
man market. A total of 372 managers are responsible for a
branch office in North or Central Europe, and 225 man-
agers for a branch office in Asia.
Results on the Significance of Company Culture
To control for the influence of different regional cultures,
only a sub-sample was used to study the significance of
company culture for internal company corruption preven-
tion. In an international sample, there would probably be
too many cultural effects to obtain a good model fit.
Therefore, Germany was selected for this multivariate
analysis as the country with the largest culturally homo-
geneous sub-sample (n = 1988).
Taking the sample of German managers, complex
structural equation modelling was used to simultaneously
analyse the cause–effect relations between various factors
of crime prevention within the German parent companies.
The goal of this analysis was, first, to identify the under-
lying prevention factors in the German compliance system
that serve as a platform for the compliance systems in
foreign subsidiaries; and second, to measure their efficacy.
A causal model was formulated that had a satisfactory
model fit and therefore provides a good reconstruction of
conditions with the help of selected model parameters. This
model can be used to deduce the significance of individual
factors for the company’s internal corruption prevention.
The significance of individual factors for a company’s
internal corruption prevention can be read off from this
4
To ensure anonymity and data protection, the survey was actually
carried out by an external company.
5
A total of 4302 managers were surveyed in this study.
6
Data were collected between the third quarter of 2012 and the third
quarter of 2014. The response rate in the individual companies ranged
from 30 to 35%.
123
K. D. Bussmann, A. Niemeczek
model (Fig. 1). It shows that, in line with Hypotheses 1–3,
a company culture that promotes integrity has a direct
influence on the following dependent variables:
1. The corruption risk within the company (own corrupt
behaviour and that seen in others) (b = -.61***).
2. Informal social control (b = .18*)
3. Positive whistleblowing culture (b = .37***)
A case scenario approach was used to study Hypothesis 1
on the corruption risk within the company. This contained
reports on own daily business behaviour (self-reports) as
well as reports on the behaviour observed in the immediate
circle of colleagues. Results confirm that a company cul-
ture that promotes integrity reduces the willingness of
managers to engage in corrupt business practices. The
influence on the dependent variable ‘corruption risk within
the company’ is direct (b = -.61***).
To study Hypothesis 2, informal social control was
operationalized with case scenarios addressing the will-
ingness to talk to colleagues about their compliance vio-
lations, to criticize them for these violations, and to discuss
observed compliance violations with colleagues. The
multivariate analysis confirms Hypothesis 2. A company
culture that promotes integrity directly increases the will-
ingness to engage in informal social control (b = .18*). If
the general climate in a company promotes integrity, this
increases the willingness to talk to colleagues about their
possible misconduct and compliance violations. In addi-
tion, this willingness is supported directly by the accep-
tance of the company’s anti-corruption programme
(b = .26***) and knowledge of norms (b = .33***).
The counterpart to informal social control is formal
reactions to compliance violations. To study Hypothesis 3,
the willingness to use a whistleblowing system is con-
ceived as an independent cultural variable. A positive
whistleblowing culture is present when whistleblowing is
associated with positive expectations and few fears about
personal consequences and consequences for one’s career.
Results indicate that such a whistleblowing culture is
strengthened by a company culture that promotes integrity
(b = .37***) and particularly strongly by the acceptance
of the company’s anti-corruption programme
(b = .60***). The latter is additionally influenced by the
internal culture over a range of other paths.
The dependent variables informal social control and
positive whistleblowing culture also have direct effects on
corruption behaviour. Whereas a high informal social
control leads to a lower tendency to engage in corrupt
practices (b = -.08, ns), a positive whistleblowing cul-
ture—because of the so-called control paradox (Bussmann
2007)—leads to franker and thereby more frequent reports
on the tendency to engage in corrupt practices among
colleagues (b = .55**).
Compliance Through Company Culture and Values: An International Study Based on the Example…
Fig. 1 Structural model of the crime prevention efficacy of anti-
corruption programmes. The structural model reveals the following
goodness-of-fit criteria: v2 = 1241.16, df = 211, CFI = .93,
TLI = .91, RMSEA = .05. The general model fit was good. Numbers
denote path coefficients. *p \ .05. **p \ .01, ***p \ .001. Cron-
bach’s alpha: tone from the top a = .781; ethical leadership a = .898;
Alongside company culture, the second significant fac-
tor reducing the risk of corruption is knowledge of the
prevailing norms regarding corruption (b = -.35***).
This confirms Hypothesis 4. These two strong direct crime-
preventing effects are additionally supported by a negative
attitude towards corruption (b = .50**).
Moreover, the multivariate analysis shows the central
role of high-quality training.7 This increases the knowledge
of norms (b = .19**), encourages an attitude that rejects
corruption (b = .28***), and increases acceptance of the
anti-corruption programme (b = .28***). As postulated in
Hypothesis 5, there is a strong interaction with company
culture (b = .64***).8 The higher the rating assigned to
training, the more frequently it is carried out, and the more
varied it is, the higher the rating on (perceived) company
culture and vice versa.
A company culture that promotes integrity has a direct
positive influence on the rejection of corruption
7
The quality of training was derived from the evaluation of
schooling measures by the managers in the survey as well as the
frequency and variety of perceived schooling and training provisions
(e.g. workshops, face-to-face sessions, online trainings).
8 9
Such a high correlation always raises a suspicion of multicollinear-
ity. Nonetheless, a test of collinearity revealed thoroughly accept-
able tolerance values of above .50. Therefore, a bias due to
collinearity can be ruled out here.
803
open communication a = .846; transparency a = .835; non-egoism
a = .739; compliance with rules a = .734; knowledge of norms
a = .362; quality of training a = .768; acceptance of anti-corruption
programme a = .786; informal social control a = .782; whistleblow-
ing culture a = .907; willingness to act corruptly a = .710
(b = .64***)9 and also impacts directly on knowledge of
norms (b = .21***). The dominant culture in a company
also impacts significantly on whether managers know
which business practices violate internal company guide-
lines or even whether a violation is a criminal offence.
It was assumed that the variables rejection of corruption,
knowledge of norms, and acceptance of the anti-corruption
programme function as moderators within the framework
of the model. This is because even without the influence of
these variables, the independent variables (e.g. integrity-
promoting culture) still show an effect on the dependent
variables (e.g. the willingness to act corruptly). Hence,
these three moderating variables influence only the size of
the effect.
The study also controlled for possible effects of per-
sonality characteristics. Analyses based on complex
structural equation models reveal that these are, at best,
only secondary to company culture, although their inclu-
sion does improve the model fit (see Bussmann 2015, for
more details).
Respondents were given items on corruption-specific attitudes
assessing their opinions on the possible advantages and disadvantages
that could arise from corruption situations both for the company and
for society.
123
804
Tone from the Top
Value management has to start on the top management
level of a company (the tone from the top). This also
applies in the present context of crime prevention: values
have to be codified, communicated, and implemented in a
top-down manner. First of all, this means that the funda-
mental values of a company have to be named in the form
of, for example, a code of ethics. For this example of a
study on corruption compliance, an effective compliance
management requires clearly communicated corruption-
rejecting values. In this way, top management lays the
foundation for its own specific company culture that inhi-
bits corruption. With the help of guidelines and rules in the
form of, for example, work directives, it exerts a regulatory
influence on daily business and thereby communicates the
main compliance message in the form of the tone from the
top.
Perceived behaviours and attitudes may well affect
several values in this, and there are also overlaps. The
multivariate analyses show that consistency, trustworthi-
ness, and open communication are significant values for the
tone from the top (Table 1). In the German parent com-
panies, nearly all the managers surveyed perceive their top
management in this way. This reveals that these companies
have already succeeded in laying the foundations for a
crime-preventing value management, and that these values
are also visible in all company contexts. At the same time,
these companies are characterized by value-based company
cultures that promote integrity. This supports the conclu-
sion that their compliance management system is embed-
ded in these values (Tables 2, 3).
Moreover, in line with Hypothesis 6, the tone from the
top is regarded as being less positive in foreign branches
and subsidiaries (see Table 4). The greatest distance is
found to managers in Asian branches. It is particularly
values expressing the trustworthiness and consistency of
Table 1 Behaviours and values perceived in top management [the
tone from the top (the set of questions on the perception of top
company management was specially developed on the basis of Steßl’s
My top management…
Would rather let a business transaction fail than have to use bribery
Resolutely backs company guidelines
Credibly conveys that bribery is not a legitimate practice
Expects business partners to take a stand against corruption
Also takes a public stand against corruption
1
Asia without branch offices in China
123
K. D. Bussmann, A. Niemeczek
top management that are not conveyed fully to managers in
Asian branches. This is possibly an effect of hierarchic-
elitist Asian cultures characterized by a greater power
distance and less generalized trust.
Ethical Leadership: Model Function
of the Immediate Superior
A sustained implementation of the desired behaviours and
values can be achieved with the help of training measures,
but it also has to be mirrored in the leadership behaviour on
all levels of management.
In general, results show that the respondents in all the
regions compared perceive their immediate superiors as
being important models. However, compared to the tone
from the top, there are recognizable weaknesses. Across all
three regions, mean scores on the tone from the top scale
(M = 4.72) differ significantly (p = .000) from mean
scores on the ethical leadership scale (M = 4.26). This
confirms Hypothesis 7. In all regions, trust in the imme-
diate superior is somewhat lower, and it is lowest of all in
the Asian branch offices. In all regions, about four-fifths of
respondents perceive behaviours expressing the value
consistency, but in the Asian branches, the superior is less
of a model (‘sets an example’, 77%) than in western
regions (each 86%).
For one-third of German managers, the immediate
superior also fails to adequately fulfil the communication
function between top management and lower management.
Only 67 per cent of German managers consider that their
immediate superior sufficiently discusses how to handle
cases of corruption in business transactions, whereas this is
viewed more positively in other regions (77 or 82%). In
Asia, far more managers report that their immediate
superior discusses cases of corruption with them and also
pays more attention to which means are applied to achieve
(2012) scale to assess illegal actions. All items were translated into
English by a professional translator)]
Percentage of agreement of managers in branch Values
offices in…
Germany North and Central Europe Asia1
95 94 85 Consistency
96 91 86 Trustworthiness
96 93 88 Trustworthiness
96 92 90 Consistency
96 88 91 Open communication
Compliance Through Company Culture and Values: An International Study Based on the Example… 805

Table 2 Perceived behaviours and values in the leadership behaviour ethical leadership scale (ELS) and partially reformulated for the
of immediate superiors [‘ethical leadership’ (the items describing the present survey)]
behaviour of the direct superior were taken from Brown et al. (2005)
My supervisor… Percentage of agreement of managers in Values
branch offices in…
Germany North and Central Asia1
Europe

Sets an example regarding how to do things the right way in terms of business 86 86 77 Consistency
ethics
Can be trusted 86 90 83 Trustworthiness
Criticizes employees who violate ethical standards 88 80 83 Consistency
Defines successes not just by results but also by the way they are obtained 77 85 82 Consistency
Listens to what employees have to say 83 87 84 Open
communication
Discusses with staff how to handle corrupt situations in business dealings 67 77 82 Open
communication
1
Asia without branch offices in China

Table 3 Values that promote careers in daily company business various authors on the topics of organizational culture, ethical
[culture of success (this concept was assessed with a specially climate, and illegal activity within an organization (Daumenlang and
constructed, theory-based scale drawing on items formulated by Müskens 2004; Eigenstetter 2006; Steßl 2012))]
Successful employees… Percentage of agreement of managers in Values
branch offices in…
Germany North and Central Asia1
Europe

Openly question management decisions if they have a good reason to do so 65 70 71 Open

communication
Address problems openly 69 83 78 Open
communication
Make business decisions transparent 67 88 83 Transparency
Deal with business partners honestly and sincerely 88 93 86 Transparency
Keep silent if others infringe company guidelinesa 7 7 13 Compliance with
rules
Neglect company guidelines if it will help to do a job wella 6 9 13 Compliance with
rules
Act on their own authority when making decisions with far-reaching 9 27 35 Non-egoism
consequencesa
Exploit their authority in the company to further their own interestsa 7 22 26 Non-egoism
a
Item was inverted in the scale
1
Asia without branch offices in China

business success. This could be due to the more critical
nature of the problems on the spot in these countries.
In sum, it can be seen that even in companies with an
advanced compliance programme, there has not been a
complete success in openly communicating the tone from
the top to lower levels—even when it comes to critical
topics such as how to deal with corruption. This applies
both for parent companies as well as the branches and
subsidiaries surveyed here. Nonetheless, it is also clear that
lower levels of management are fully aware of their per-
sonal responsibility and contribute to open communication
in the company. In the North and Central European branch
offices as well as in those in Asia, managers seem to be
particularly aware of their special role in engaging in open
communication and maintaining the central compliance
message of the parent company, and they invest more in
setting a good example than managers in German parent
companies.

123
806 K. D. Bussmann, A. Niemeczek

Table 4 Group means on the survey scales and results of a U test of significant group differences
Scale Means of managers from… Germany versus Asia1 North and Central Europe versus Asia1
Germany North and Central Europe Asia1 U p U p

Tone from the top 4.74 4.68 4.56 344,830.5* .017 40,242.5 .376
Consistency 4.47 4.51 4.38 223,229.5 .972 39,701.0 .275
Trustworthiness 4.63 4.67 4.51 218,906.0 .568 38,342.0 .052
Open communication 4.11 4.23 4.26 262,450.0*** .000 44,698.5 .160
Transparency 4.20 4.50 4.36 258,508.0*** .000 38,626.5 .085
Non-egoism 4.06 3.68 3.42 152,647.0*** .000 36,416.0* .012
Compliance with rules 4.12 4.22 4.07 227,203.0 .597 38,959.0 .166
* p \ .05. *** p \ .001
1
Asia without branch offices in China

Culture of Success in a Company Culture
that Promotes Integrity
Although top and middle management codify the binding
rules and try to set a good example by modelling the values
of their company in their work, a company culture that
promotes integrity and its values needs to become inter-
nalized on all management levels. This also requires the
certainty that these values will not stand in the way of one’s
personal career. Therefore, respondents were not asked
about potentially idealized value orientations but only
about the significance of values with which they can also
succeed within their company. Only then will there be
sufficient incentives for business practice to be guided by
the specific company value orientations. This culture
among managers is labelled the culture of success. It is
defined as those behaviours that lead to a successful career
in the company.
Therefore the study asked: ‘Companies place a variety
of demands on their employees. What makes a successful
employee stand out in your company?’
Managers in the three regions differ in their perceptions
of the value of open communication. The largest difference
is found between German managers on one side and North
and Central European as well as Asian managers on the
other. German managers seem to perceive a frank discus-
sion of problems or concrete management decisions in
daily business as being less favourable for their own
careers.
All regions assign a relatively high significance to the
value of transparency. Values such as open communication
and transparency are central pillars of the culture managers
perceive on all levels and under different regional cultural
conditions. There are overlaps between these two values,
and they also interact. Transparency should be understood
as more of a structure-forming value that makes informa-
tion, procedures, or decisions recognizable and
understandable for all relevant company employees along
with others involved with the company. Whereas trans-
parency grants access to information, open communication
additionally calls for actively passing on information and
reflecting on it. This value emphasizes both the sending of
compliance messages and an uncensored consideration of
them (such as discussing corruption situations, being open
to the concerns of employees, and questioning management
decisions).
Similar support is given to the value compliance.
Roughly nine out of ten managers in Germany and in the
European and Asian regions surveyed consider their com-
pany’s guidelines and rules to be unconditionally binding.
Only a very small group view keeping silent about viola-
tions and neglecting company guidelines to achieve suc-
cess as being part of their own culture of success. However,
such managers were found more frequently in Asian
subsidiaries.
These companies seem to have succeeded to a high
degree in establishing compliance as a value abroad as
well. Even in the case of short-term individual interests, the
majority of managers consider that the company values
guide their actions. Moreover, even in Asian cultures, these
companies have already succeeded in establishing a solid
compliance basis that draws on a shared understanding of
the rules among managers.
Things look different when it comes to acting in one’s
own interest and exploiting one’s own authority as part of
one’s own culture of success. In the German parent com-
panies, less than one in ten view this as giving them a
career advantage in their company. Among managers in
other European and Asian branch offices, this proportion
increases threefold. Here, one in three to four managers
sees a possible career advantage from acting in their own
interest. The basic rejection of egoism, which finds a high
degree of consensus in German parent companies, already

123
Compliance Through Company Culture and Values: An International Study Based on the Example…
weakens in branch offices in neighbouring countries and is
much weaker in more distant branch offices in Asia.
Results on the Meaning of Corporate Values
In the following, Hypotheses 8–13 on the different regional
levels of values are analysed with significance tests
(Table 4). These show that only H12 can be confirmed.
Managers in Asian branches perceive acting in their own
interest and exploiting their own authority to be more
strongly a part of the company culture than managers in
German parent companies and North and Central European
branch offices. The rejection of acting in their own interest
is particularly significant in terms of the identity-promoting
effect of values. Acting in one’s own interest particularly
expresses a lack of community orientation and thereby
characterizes the lack of cohesion found among members
of a company.
All further hypotheses (H8–H11, H13) cannot be con-
firmed. There is a tendency for managers in Asian branch
offices to perceive consistency, trustworthiness, and com-
pliance with rules as being less part of the company culture
than managers in German parent companies and North and
Central European branch offices (H8, H9, H13). However,
these differences fail to attain statistical significance.
In addition, some significant differences take an unex-
pected direction. For example, the values open communi-
cation and transparency are perceived as being stronger in
foreign branch offices than in the German parent compa-
nies. This difference attains significance between German
and Asian managers. Hence, in the sample studied here,
there is only partial confirmation that a hierarchic-elitist
Asian culture characterized by a greater power distance
and less generalized trust inhibits the culture of integrity in
German companies.
Willingness to Engage in Corrupt Behaviour
in Competitive Situations
The risk of corruption in a company is finally an expression
of how managers and employees deal with corruptive sit-
uations in their daily business. However, any replies to
questions on such sensitive issues will be influenced
strongly by social desirability effects. Therefore, alongside
self-reports, we also asked respondents to rate other
employees. We asked them to tell us how probable they
considered it to be that colleagues would either accept a
bribe from or give a bribe to a potential business partner in
a competitive situation.
The proportions of those who are certain that their
colleagues would act corruptly in such a situation as well as
the proportions of those who are uncertain about how their
colleagues would behave hardly differ between Germany
807
and North or Central Europe (see Fig. 2). In Germany and
North and Central Europe, roughly one in ten managers is
uncertain about the integrity of her or his colleagues.
However, clearer differences emerge when these regions
are compared to branch offices in Asia. In Asia, the pro-
portion of those who are certain that their colleagues would
act corruptly is more than twice as high as in Germany or
Europe. Additionally, more than one in ten managers in
Asia are uncertain about how colleagues would behave in a
competitive situation in which they are confronted with
giving or taking a bribe. For the Asian branch offices of
German companies, this results in a risk group of one-fifth
of all employees whose integrity is questionable. In Ger-
many and other European branch offices, only roughly one
in ten belong to this risk group.
These differences also prove to be statistically signifi-
cant. Hence Hypothesis 14 can be confirmed: managers in
Asian branch offices report a greater willingness to act
corruptly in daily business than their German and North or
Central European colleagues.10
This shows that particularly in Asian countries, German
companies face greater obstacles in the implementation and
efficacy of their compliance programmes than in directly
neighbouring European countries. This may also be due to
a greater difference between cultures.
Discussion
The multivariate analysis reveals the central significance
that an integrity-promoting corporate culture has for many
of those factors that have crime-preventing effects. Such a
culture has a directly significant effect that reduces the
willingness to act corruptly (Fig. 1). It also has a direct
effect on the support for both informal social control and a
whistleblowing culture. Here as well, the multivariate
analysis reveals that alongside the company culture,
training in knowledge of the norms is important, whereas
this, in turn, is also influenced positively by the company
culture. An effective company culture does not just depend
on the tone from the top in the company’s top management
and the ethical leadership of direct superiors but also on
training courses, with results showing a strong interaction
between high-quality training and company culture.
Nonetheless, the multivariate analysis has to be restric-
ted to the German sub-sample, because the international
sample would probably produce too many cultural effects
to achieve a good model fit. An internationally valid model
10
Group comparisons of the appraisal of corruptive behaviour in
Germany versus Asia v2 = 17.914***, p = .000 and in North and
Central Europe versus Asia v2 = 14.791***, p = .001 (Asia without
branch offices in China).
123
808
8%
3%
2%
Germany North & Central Europe
(rather) yes
Fig. 2 Appraisal of whether colleagues would give or take bribes in a competitive situation
would therefore have to take more cultural dimensions into
account in each country. This weakness will be addressed
in a continuation of the research project.
The study also permits no statements on the compliance
situation for all German companies and their foreign sub-
sidiaries, because data were collected exclusively in com-
panies with an advanced compliance programme. Hence a
real control group is lacking. This methodological weak-
ness will also be addressed in a future project.
Nonetheless, the study does permit the analysis of the
postulated relations—particularly those on the significance
of the company culture. In contrast to compliance-based
cultures, value-based company cultures strive to achieve an
internalization of a company’s own values that should
guide employees and promote their integrity independent
of concrete rules. The companies in the present survey can
be assigned to this second phase in the development of
culture and compliance, as is revealed particularly in the
results on the dimensions of a company culture that pro-
mote integrity. Hence, the study makes it possible not only
to analyse the significance of a company culture but also to
make generalized statements for companies with value-
based company cultures. Therefore, it is representative of
these companies.
To the extent that scores on the values of German
companies can also be compared with those in their foreign
subsidiaries, several of the hypotheses cannot be confirmed
(see Table 4). Counter to Hypotheses 8–13, hierarchic-
elitist regional cultures do not necessarily influence com-
pany cultures by impeding integrity. Evidently, compliance
with the rules can be established as an independent value
even under the influence of foreign local cultures. In the
present sample, Asian managers (without China) in Ger-
man companies reveal no significant differences on the
values consistency and trustworthiness compared to Ger-
man managers or managers from other North and Central
European subsidiaries. These two values are conveyed
above all by the behaviour of top management and that of
direct superiors in the company. Evidently, German com-
panies succeed in conveying the tone from the top to the
123
K. D. Bussmann, A. Niemeczek
12%
7% 7%
Asia
uncertain
non-German managers in their foreign subsidiaries so that
their perception of the compliance message from top
management is not impaired by cultural differences.
Nonetheless, the value of non-egoism scores signifi-
cantly higher in the group of German managers (H14).
Conceivably, managers in the German parent companies
and other North and Central European subsidiaries place
less emphasis on their own interests, so that their business
decisions are shaped less by egoism than those of the Asian
managers. In collectivist societies, these ‘own interests’ are
frequently the interests of one’s own reference group,
which may be the family or also the proximal working
environment. Favouring this reference group is often dri-
ven by a notion of care that is characteristic for a collec-
tivist value orientation and is found particularly in
hierarchic-elitist societies.
However, when it comes to the values transparency and
communication, it is not clear whether one can actually
assume higher levels in Asian countries with a collectivist
value orientation. It is even conceivable that a greater
willingness to communicate may reveal positive effects of
a collectivist compared to an individualistic regional cul-
ture. A decisive examination of this and further aspects of
the company culture and the culture of success will have to
wait until the second stage of this research project that will
include cultural comparisons between groups in different
countries.
Nonetheless, the present study can confirm the hypoth-
esis that hierarchic-elitist cultures promote corruption
(H14). Asian managers in German companies reveal a
significantly higher willingness to apply corrupt practices
in daily business compared to German managers and
managers in North and Central European subsidiaries
(Fig. 2).
Compliance Through Company Culture and Values: An International Study Based on the Example…
Conclusion
It can be seen that compliance management is a complex
task that can be achieved only in combination with a
company climate that promotes integrity. Provision for this
is made in the international legal regulations and the
recently published international ISO 19600 standard for
compliance management systems. However, the commu-
nication of normative limits such as business ethics
requires a company culture that promotes integrity. A
successful compliance management cannot be limited to
imparting knowledge of the laws, providing guidelines, and
imposing controls. Rule-based and value-based compliance
management are not alternatives but complement each
other (Verhezen 2010). The need is to communicate values
that promote and internalize integrity in different contexts
in a way that supports knowledge of the norms and
simultaneously conveys the all-embracing principles of the
company.
Hence, compliance management, as studied here for the
example of corruption prevention, has to be viewed as a
thoroughly complex cross-sectional task that needs to
include all levels and contexts of a company. Without the
successful transfer of a tone from the top and the ethical
leadership of the immediate superior, no effective com-
pliance management is possible.
Compliance management needs the support of a general
culture of values that has to be experienced as not impeding
but promoting careers. Above all, it has to place value on
trustful and frank discussion among managers. Alongside
this orientation towards communication, it requires con-
sistency and trustfulness as central values—particularly on
upper management levels. Guidelines will be accepted and
adopted only when top management together with middle
management serve as models by being uncompromising,
positioning themselves openly, sanctioning violations
consistently, and so forth.
Such a company culture should not be viewed as static.
It can be shaped in a direction that promotes integrity
through top management, middle management, and train-
ing courses. Training measures can decisively support a
change of culture. They do not just make it possible to
communicate guidelines and rules within the company but
simultaneously transport values that promote integrity.
They represent a medium for the company values that
promotes integrity and leads to an integrity-oriented oc-
cupational socialization comparable to the primary or
secondary socialization found in the family, circle of
friends, and school that helps prevent crime in general
(Bussmann 2015).
However, companies face major challenges when
transferring their culture to foreign subsidiaries.
809
Nonetheless, the results of the present study show that the
companies surveyed here have basically succeeded in
establishing their value system among non-German man-
agers in Asian subsidiaries. Hence, compliance can also
succeed in countries with a strongly collectivist value ori-
entation. Nonetheless, the stronger collectivist orientation
in Asian countries is still reflected in a greater willingness
to behave and make decisions in one’s own interest in
everyday business. A greater willingness to engage in
corrupt business practices can also be confirmed. This
reveals the effect of a society shaped more strongly by
power distance in which hierarchies, responsibilities, and
decision-making powers are questioned more rarely or with
more reserve.
As the cross-cultural comparisons show, companies that
possess an established compliance and value management
can succeed in taking what has become a broadly well-
established company culture to promote integrity in Ger-
many and transferring it to their foreign branch offices.
This grants them a sociopolitical function that should not
be underestimated. Of course, companies can hardly create
the socio-structural and institutional preconditions to fight
corruption in a country such as rule of law; freedom of
opinion, the press, and demonstration; and the corre-
spondingly independent institutions. However, they can
make an important contribution to cultural change by not
only pursuing an anti-corruption policy in their daily
business but also implementing a culture that promotes
integrity in their company.
One reason why major companies can make a
sociopolitical contribution to changing local value orien-
tations and everyday norms that encourage corruption is
the fact that they reach a large part of the working-age
population. The significance of major international com-
panies should also not be underestimated, because the
companies in the present sample also exert a strong pres-
sure for compliance on their dependent supply chains in
order to avoid controversy themselves (Bussmann 2015).
In this sense, their compliance programme could spread to
foreign business cultures and eventually to the rest of a
society as well.
References
Akers, R. L. (2013). Criminological theories: Introduction and
evaluation. London: Routledge.
Berry, B. (2004). Organizational culture: A framework and strategies
for facilitating employee whistleblowing. Employee Responsi-
bilities and Rights Journal, 16(1), 1–11.
Bhal, K. T., & Dhadich, A. (2011). Impact of ethical leadership and
leader–member exchange on whistle blowing: The moderating
impact of the moral intensity of the issue. Journal of Business
Ethics, 103(3), 485–496.
123
810
Björnskov, C., & Paldam, M. (2004). Corruption trends. In J. Graf
Lambsdorff, M. Taube, & M. Schramm (Eds.), The new
institutional economics of corruption (pp. 59–75). London:
Routledge.
Brown, S. E., Esbensen, F. A., & Geis, G. (2013). Criminology:
Explaining crime and its context (8th ed.). New York:
Routledge.
Brown, M. E., Treviño, L. K., & Harrison, D. A. (2005). Ethical
leadership: A social learning perspective for construct develop-
ment and testing. Organisational Behavior and Human Decision
Processes, 97, 117–134.
Bussmann, K.-D. (2007). The control-paradox and the impact of
business ethics: a comparison of US- and german companies.
Monatsschrift für Kriminologie und Strafrechtsreform, 2(3),
260–276.
Bussmann, K.-D. (2015). The impact of personality and company
culture on company anti-corruption programmes. In J. Van Erp,
W. Huisman, & G. V. Walle (Eds.), The Routledge handbook of
white-collar and corporate crime in Europe (pp. 435–452).
London: Routledge.
Chin, W. W. (1998). Issues and opinion on structural equation
modeling. MIS Quarterly, 22(1), 7–16.
Christie, P. M. J., Kwon, I.-W. G., Stoeberl, P. A., & Baumhart, R.
(2003). A cross-cultural comparison of ethical attitudes of
business managers: India, Korea and the United States. Journal
of Business Ethics, 46, 263–287.
Daumenlang, K., & Müskens, W. (2004). Fragebogen zur Erfassung
des Organisationsklimas (FEO). Handanweisung. Göttingen:
Hogrefe.
de Bruin, B. (2016). Pledging integrity: Oaths as forms of business
ethics management. Journal of Business Ethics, 136, 23–42.
Eigenstetter, M. (2006). ECQ—Ethical climate questionnaire—Ger-
man version. Lengerich.
Eigenstetter, M., Dobiasch, S., & Trimpop, R. (2007). Commitment
and counterproductive work behaviour as correlates of ethical
climate in organizations. Monatsschrift für Kriminologie und
Strafrechtsreform, Sonderheft, 2(3), 224–244.
Ferrell, O. C., Fraedrich, J., & Ferrell, L. (2015). Business ethics.
Ethical decision making and cases (10th ed.). Stamford:
Cengage Learning.
Getz, K. A., & Volkema, R. J. (2001). Culture, perceived corruption,
and economics: A model of predictors and outcomes. Business
and Society, 40(1), 7–30.
Graf Lambsdorff, J. (2007). The institutional economics of corruption
and reform. New York: Cambridge University Press.
Grasmick, H., Bursik, R., & Arneklev, B. (1993). Reduction in drunk
driving as a response to increased threats of shame, embarrass-
ment, and legal sanctions. Criminology, 31, 41–67.
Hofstede, G., & Minkov, M. (2013). Values survey module 2013
manual. Available at http//:www.geerthofstede.com/media/2186/
Manual%20VSM%20%202013%202013%2008%2025.docx.
Accessed 18 Jan 2016.
House, R. J., Hanges, P. J., Javidan, M., Dorfman, W. P., & Gupta, V.
(2004). Culture, leadership, and organizations: The GLOBE
study of 62 societies. Thousand Oaks: Sage.
International Standard ISO 19600. (2014). Compliance management
systems-guidelines. Geneva: ISO Copyright Office.
Jöreskog, K. G. (1970). A general method for analysis of covariance
structures. Biometrika, 2(57), 239–251.
Kaptein, M. (2011). Toward effective codes: Testing the relationship
with unethical behavior. Journal of Business Ethics, 99,
233–251.
Karstedt, S. (2003). Macht, Ungleichheit und Korruption: Strukturelle
und kulturelle Determinanten im internationalen Vergleich
[Power, inequality, and corruption: An international comparison
123
K. D. Bussmann, A. Niemeczek
of their structural and cultural determinants]. Soziologie der
Kriminalität, Sonderheft der KZfSS, 43, 384–412.
Kline, R. B. (2011). Principles and practice of structural equation
modeling methodology in the social sciences. New York:
Guilford Press.
Kölbel, R. (2015). Whistleblowing in Europe. Regulatory frameworks
and empirical research. In J. van Erp, W. Huisman, & G.
V. Walle (Eds.), The Routledge handbook of white-collar and
corporate crime in Europe (pp. 418–434). London: Routledge.
La Porta, R., Lopez-de-Silanes, F., Shleifer, A., & Vishny, R. W.
(1999). The quality of government. Journal of Law Economics
and Organization, 15(1), 222–279.
Lind, E. A. (1994). Procedural justice and culture: Evidence for
ubiquitous process concerns. Zeitschrift für Rechtssoziologie,
15(1), 24–36.
Messner, S. F., & Rosenfeld, R. (2007). Crime and the American
dream (4th ed.). Belmont, CA, USA: Thomson/Wadsworth.
Miceli, M. P., & Near, J. P. (2002). What makes whistle-blowers
effective? Three field studies. Human Relations, 55(4), 455–479.
Nagin, D. S., & Paternoster, R. (1994). Personal capital and social
control: The deterrence implications of a theory of individual
differences in criminal offending. Criminology, 32, 581–606.
Nunner-Winkler, G. (2004). Sociohistoric changes in the structure of
moral motivation. In D. K. Lapsley & D. Narvaez (Eds.), Moral
development, self, and identity Mahwah (pp. 299–334). New
York: Lawrence Erlbaum.
Paldam, M. (2002). The big pattern of corruption: Economics, culture
and the seesaw dynamics. European Journal of Political
Economy, 18, 215–240.
Rothschild, J., & Miethe, T. D. (1999). Whistle-blower disclosures
and management retaliation: The battle to control information
about organization corruption. Work and Occupations, 26(1),
107–128.
Rothwell, G. R., & Baldwin, J. N. (2006). Ethical climates and
contextual predictors of whistle-blowing. Review of Public
Personnel Administration, 26(3), 216–244.
Scholtens, B., & Lammertjan, D. (2007). Cultural values and
international differences in business ethics. Journal of Business
Ethics, 75, 273–284.
Schumacker, R. E., & Lomax, E. G. (2015). A Beginner’s guide to
structural equation modeling (4th ed.). London: Taylor &
Francis.
Simons, T., Leroy, H., Collewaert, V., & Masschelein, S. (2015).
How leader alignment of words and deeds affects followers: A
meta-analysis of behavioral integrity research. Journal of
Business Ethics, 132, 831–844.
Sims, R. (2009). Collective versus individualist national cultures:
Comparing Taiwan and U.S. employee attitudes toward uneth-
ical business practices. Business and Society, 48(1), 39–59.
Steßl, A. (2012). Effektives compliance management in unternehmen.
Wiesbaden: Verlag für Sozialwissenschaften.
Tonoyan, V. (2004). The bright and dark sides of trust: Corruption
and entrepreneurship—A cross-cultural comparison of emerging
vs. mature market economies. Available at http://www.icgg.org/
downloads/contribution11_tonoyan.pdf. Accessed 18 Jan 2016.
Tyler, T. R. (1990). Why people obey the law. New Haven: Yale
University Press.
UK-Bribery Act. (2010). Available at http://www.legislation.gov.uk/
ukpga/2010/23/pdfs/ukpga_20100023_en.pdf.
US-Foreign Corrupt Practices Act (2004). Available at http://www.
justice.gov/criminal/fraud/fcpa/docs/fcpa-english.pdf.
Uslaner, E. M. (2005). Trust and corruption. In J. Graf Lambsdorff,
M. Taube, & M. Schramm (Eds.), The new institutional
economics of corruption (pp. 76–92). London: Routledge.
Valentine, S., Nam, S.-H., Hollingworth, D., & Hall, C. (2014).
Ethical context and ethical decision making: Examination of an
Compliance Through Company Culture and Values: An International Study Based on the Example…
alternative statistical approach for identifying variable relation-
ships. Journal of Business Ethics, 124, 509–526.
Verhezen, P. (2010). Giving voice in a culture of silence. From a
culture of compliance to a culture of integrity. Journal of
Business Ethics, 96, 187–206.
Viswesvaran, C., & Ones, D. S. (2002). Examining the construct of
organizational justice: A meta-analytic evaluation of relations
with work attitudes and behaviors. Journal of Business Ethics,
38, 193–203.
811
Weaver, G. R., Treviño, L. K., & Cochran, P. L. (1999). Corporate
ethics programs as control systems: Influences of executive
commitment and environmental factors. The Academy of Man-
agement Journal, 42(1), 41–57.
Worrall, J. L., Els, N., Piquero, A. R., & TenEyck, M. (2014). The
moderating effects of informal social control in the sanctions-
compliance nexus. American Journal of Criminal Justice, 39(2),
341–357.
123