“Tone at the top!” “Clean the staircase from the top!” “The fish rots at the head.” Popular maxims such as these reflect the widely held belief that it is the leaders of an organization who are responsible for instigating and sustaining a corporate culture which encourages employees to behave ethically. Corporate ethics management initiatives therefore invariably start with an effort to secure the board and executive leadership's commitment to the proposed program. What is implicitly assumed in all of this is that it is primarily those in the top echelons of the corporate hierarchy who have to be convinced of the need for an ethics program. An assessment of the ethical risks that the organization faces is often deemed a sufficient rationale. It is believed that once its captains are aware of the dangerous state of affairs, the corporate ship will retrieve its moral compass. The overhaul of an organizational culture is therefore largely seen as a top-down affair, with leadership setting the tone, implementing ethics management initiatives and leading by example.

That high-level individuals can and do play an important role in articulating priorities and shaping the sensibilities of employees within organizations is not to be disputed. However, if the role of such individuals is not to be denied, it is also not to be overestimated.