Chapter 5

The institutional perspective

There is a dual correlation between human centered management and institutions: institutions influence the attitudes and behaviors of leaders, and moral leaders exert an influence on institutions. The former is seen in public and private educational institutions and also in ideological and professional associations; the latter gave birth to creeds and thought systems that became known through an outstanding leader’s ideas, words and actions, such as Christianity, Islam, Buddhism or Gandhism, and are institutions of their own. Governmental institutions that play a major role in shaping the bonds within a society are not necessarily based on a thought system or an ideology – an example is the Chinese free market system (adapting a “Western” ideology) that works under a communist scheme. But any institution, governmental, educational or professional, needs a framework or frameworks for defining its policy agenda, and most have an ethical content. Managers who work there will not automatically have to abide by these policies – they should be given a chance to shape them, as will be discussed in the first part of this chapter. The second part will then take up the question of how an ethical policy agenda works in governments. This will be preceded by a brief passage on the outlines of institutional theory and how it relates to the human centered paradigm.

The relation between institutional theory and the human centered paradigm can best be inferred from a definition given by Stanford Professor William Richard Scott (see Scott 2004): “a theory on the aspects of social structure, considering the processes by which structures, including schemes, rules, norms, and routines, become established as authoritative guidelines for social behavior.” Social/moral behavior is the individual aspect. There is a business aspect as well, which is marked by Nobel laureate Douglass Cecil North (1920–2015). He argued that for economic change, entrepreneurs depend on institutional changes, for example, new structures of public administration. The business sector’s systematic investment in skills and their application to the economy, he wrote, must entail and cannot prevail without the (public) institutions: “The institutional framework directs the process of human learning and the development of tacit knowledge that leads the decision-making processes” (North 1990, p. 80). Institutions and business firms interfere with each other mutually.

The mutual interference is more intense in some industries and less so in others. Managers employed in construction, or in financial services, will experience intervention from public institutions in their day-to-day work; on the other hand, management in these industries must seek to be involved in shaping the rules, norms and routines that guide these interventions. Institutional intervention is needed in a society to prevent and correct failures in the market, and to prevent and correct immoral behavior. A society which does not have good working institutions will fail to provide the common good to its members. An institutional void, that is, ineffectiveness or inefficiency or complete absence of a public authority will also hinder all efforts to build markets in less developed countries that would provide economic and social development. Expatriates that are deployed into this type of economies need to be especially aware of these deficiencies. Property rights and autonomy, which are taken for granted as pillars of markets in modern societies and economies, often stand in conflict with existing rules of the game in societies that adhere to patriarchy, corruption and patronage in business dealings.

A complete “void” of institutions can scarcely be imagined for even the least developed country, but when it comes to remote rural communities in those countries, the rule of law that might be upheld, at least purportedly, in the capital, does not exist at all. There are examples where Nestlé started its Pure Drinking Water Supply Project and Unilever launched a social initiative to encourage women’s economic empowerment in rural Bangladesh (Uddin, Tarique, and Hassan 2008). The obstacles were not just patriarchy and corruption, but also the religious concept of purdah, a manifestation of the belief that Allah made women weaker (Mair, Martí, and Ventresca 2012). The international managers of these companies, when training for assignments like to Bangladesh, may have learned about the cultural differences or institutional distances (see, e.g., Ojala 2015) between their home country and the host country. But, when their job requires displacement throughout the regions of, for example, Bangladesh, they will have come to terms with the more complicated issue of institutional distances within the host country.

The international dimension of institutionalist theory illustrates the far-reaching responsibilities of business managers who handle public institutions relations, or who have to step in when public institutions are weak. Viewed from the other way round, it is the responsibility of managers in public institutions, at home and abroad, to reach out to all members of society, and that includes business. In the first place, they have to set up a concise agenda, and then their activities and decisions must be moral to the point of being above any doubt.

5.1 Policy agendas

For any institution, the challenge is to have a clear map of the impact its activities have on society and a clear strategy to ensure that its operations and performance carry through the direction provided by its leadership. This is a question of matching the institution’s purpose, strategy, principles and governance with daily management routines. What has to be prevented is decisions being made independently of social context and without regard to the attitudes and behavior of stakeholders. But it must be accepted that completely other-regarding behavior, such as altruism and altruistic or third-party punishment, cannot be fully captured in any societal or economic environment. There is a wide span between these extremes, and in order to find the proper balance an institution may opt for regulating the institution’s operations through a set of compliance rules or through appealing to the accountability of its decision-makers. The first alternative would be based on the perception that the market rewards moral behavior and that there are extrinsic mechanisms in the market that guide moral decision-making. The second alternative is led by the belief that decision-makers will feel intrinsically committed to choose a morally acceptable option.

5.1.1 A moral market framework

A moral market framework is not about formal regulations by laws and ordinances that direct decision-making, but rather about (informal) mechanisms that punish immoral behavior. As we have seen from the repeated uncovering of the many corporate offenses against morality (from the Enron and WorldCom cases to Siemens and Volkswagen), there undoubtedly is such a mechanism. Using the argument in a positive way, with economic decisions, behaviors, and institutions depending on and influencing moral/ethical sentiments and behaviors, a distinct statement can be made that all economic systems are founded upon ostensible norms governing what is deemed morally acceptable in fair relations between the economic actors and with institutional actors. This would extend to norms that are deemed to produce an appropriate distribution of economic output and to questions concerning the relationship of economic activities to broader societal welfare: “Every economy is a moral economy” has been said by, among others, British political theorists and philosophers Andrew Sayer and Russell Keat (see Sayer 2007).

Sayer and Keat offer two meanings of the concept of morality (Kennedy 2012), both of which have been taken up in this book. One is what good (= moral) behavior consists of, for example, what would constitute a life worth living, what would contribute to people’s well-being and what would be best for them to pursue as goals or ends. The other refers to claims about the rules that should govern people’s relationships with one another, the proper limits on their pursuit of their own interests and the principles upon which income, wealth or opportunities should be distributed. At this stage of the book, we are concerned with rules governing relationships in the economic and political world and with the limits these rules should set to the pursuit of the interests of one party. An illustrative example, on the scale of global economic relationships, are the endeavors of the European Commission, representing a leading player in these relationships, to implement economic partnership with less developed countries in Africa, the Caribbean and the Pacific.

The European Union (EU) has a long history of being looked at as a benevolent development actor in its trade relationship with the African, Caribbean and Pacific (ACP) countries. Economic ties to these partners have been moralized in relation to development norms and ACP–EU trade has been envisioned as a basis for poverty elimination for vulnerable peoples (see, e.g., Brown 2002). European policy-makers have taken great care to update these moral development underpinnings.

One of the foremost issues is the EU’s contribution to complementary adjustment policies destined to balance the effects of what some critics have seen as premature opening up of markets. These policies typically involve labor market reforms to enhance the mobility of the workforce both between and within industries and training programs to provide qualified employees for export-oriented companies and technological support to improve the ability of firms to compete against imports. By aligning with this policy discourse, the European Commission is defining viable strategies for creating decent jobs while respecting the ACP states’ autonomy to protect an emergent domestic industrial and agricultural sector (Szépesi 2004).

While there are still concerns about labor standards in low-value and low-pay export industries such as cut-flower production (Langan 2013), the co-operative power of EU engagement is well acknowledged, as seen in the African Peace Facility 2015 Annual Report (European Union 2016).

The ACP–EU agreements demonstrate how marketplace morality induces negotiators to consider the interests of stakeholders and to pursue both their own interests and those of their business partners. Leaders in a market such as the EU when dealing with less developed countries have an obligation, based on what must be viewed at as an extended social contract, to act consistently with this marketplace morality. Their guidelines would be what Donaldson and Dunfee have called the universal norms or hypernorms, such as basic rights of freedom, movement, free speech and nondiscrimination. They suggest the use of presumptions as a means of identifying if an ethical principle is widespread. Evidence in support of a principle having hypernorm status would be, according to Donaldson and Dunfee (1999), that it is, inter alia:

• A component of well-known global industry standards;
• Supported by prominent non-governmental organizations such as the International Labor Organization or Transparency International;
• Consistently referred to as a global ethical standard by international media;
• Known to be consistent with precepts of major religions;
• Supported by global business organizations such as the International Chamber of Commerce or the Caux Round Table;
• Known to be consistent with precepts of major philosophies;
• Generally supported by a relevant international community of professionals, e.g., accountants or environmental engineers;
• Supported by the laws of many different countries.

All these qualities demonstrate that there is indeed moral capacity in the markets and in the rules that govern markets.

5.1.2 Accountability frameworks

The traditional corporate formula for accountability, where the company represents the interests of the shareholders and its performance is measured in profit and growth, has long been overruled by the demand that corporate accountability become deeper and broader. One may question whether, as is frequently claimed, this demand was brought in through pressure groups from outside. If we look at 19th-century social agendas, of which Cadbury’s and Robert Owen were examples as discussed earlier, the demand was intrinsic to the firms or the firms’ owners. Today, companies in general are moving beyond a single financial bottom line towards a triple bottom line that also encompasses social and environmental accountability and responsibility for wider public goods.

Like governments and their agencies that are, in the end, accountable to voters, the corporations’ accountabilities extend to all stakeholders. And in both the public and the corporate sector, strong financial management and accountability is driving continual improvement in governance. So there is a beneficial consequence: accepting wider accountability will enhance best practices and thus increased performance throughout the whole organization.

With extended accountabilities in both the public and the private sectors, the issue is not whether one should emulate the other. Rather, it is about evaluating the practices of other organizations, whether they are private or public, and then implementing the best of these practices. This also relates to information disclosure. Social accounting and reporting has become a practice of businesses of any size – from the small firm describing how it trains apprentices and has been certified by environmental auditors to the large corporation with expertise in dealing with labor relations worldwide and specialists for all sorts of ecological concerns. What this type of accounting basically reveals is that firms and their leadership not only feel that they are accountable for their decisions’ moral impact (i.e., the impact on society) but also make public the scale of this accountability.

The organization with the most notable policy agenda affecting all sectors of society and with a clear-cut accountability scheme is the United Nations Human Rights Council (UNHRC). The UNHRC is an intergovernmental body whose 47 member states are responsible for promoting and protecting human rights around the world. It was established in 2006, replacing the UN Commission on Human Rights, which had been set up in 1946 to determine a drafting committee for the Universal Declaration of Human Rights, adopted by the United Nations on December 10, 1948.

After its establishment, the Human Rights Council issued a regime of periodic reviews of all 193 UN member states, with information based on reports coming from three different sources: the government of the state under review, authorities of the UN and local stakeholders including national human rights institutions, and civic associations and other civil society actors. Each review is facilitated by a group of three rapporteurs, which are states outside the review area. They have to prepare an outcome document on the review, which includes a summary of the review proceedings, recommendations, conclusions and voluntary commitments presented by the state under review. With the local stakeholders being entitled to report on any observation they make on human rights abuse in a business or a government authority, both the corporate and the public sector may come under tight scrutiny. This is what the mechanism intends, enforcing the accountability of non-state actors and enforcing respect for, for example, codes of conduct, trade union laws and rights of association.

A forerunner of the Human Rights Council, at least in fighting abuse of fundamental rights of workers and engaging all relevant actors in its operations from the beginning, is the International Labour Organization (ILO), created in 1919 as an agency of the League of Nations following World War I. Using a tripartite structure of representation, the ILO ensured the participation of business, labor and governments in developing worker rights and minimum labor standards for member states. It was in the interest of business that universal standards contributed to minimize competitive distortions. The ILO and the UNHRC work closely together, with the former providing concepts, training and programs on emerging issues such as the situation of migrants, and the latter exercising control through the reporting scheme.

There is another group of institutions in society apart from government and business whose importance and involvement is growing, and this is the third sector – voluntary and community organizations, lobbyists, charities, charitable trusts, civic associations, self-help groups, social enterprises, mutual societies and co-operatives and other non-profit organizations (civil society organizations, or CSOs). They focus on social services, the environment, education and other issues that are deemed to be unmet needs in a society.

Peter Drucker suggested that the non-profit sector provides an excellent outlet for a variety of society’s labor and skills (Drucker 1995), and in the US, approximately 10% of gross domestic product (GDP) is attributable to the third sector (Salamon and Sokolowski 2004). With this magnitude, it sounds logical that non-profit organizations not only have a financial accountability towards the communities by which they are sponsored, but that there is also a strong imperative for holding them accountable for their activities. However, with many CSOs, several important questions are left unanswered (Onyx 2008):

• To whom is the organization accountable, and for what?
• How is this accountability to be demonstrated, and what compliance mechanisms are available and necessary to ensure that the organization remains within its accepted zone of conduct?
• Put another way, who has (or should have) the power to enforce compliance, and if this is the state, does such power potentially curtail the capacity of the organization to operate autonomously?

With the wide array of activities that CSOs pursue – sometimes overlapping, even contradictory, including the exertion of pressure and other questionable means, the need for holding them accountable has become even more important. In most cases, CSOs present a serious concern of a group of people or they take up the concerns of less powerful people. Many of the larger ones such as Greenpeace, the World Wildlife Federation (WWF) and Oxfam have offices all over the world, but there are myriad smaller ones (e.g., it is estimated that the number of CSOs in the UK was more than 900,000 in 2011–2012, with an estimated 2.3 million people employed as paid staff; see NCVO 2014). From their omnipresence, it becomes obvious that they can exert a substantial influence on the moral behavior of corporate officers and leaders.

The stake that CSOs hold in a corporation is very different from that held by other stakeholder groups, all of which have a direct, mostly contractual, relation to the firm. By contrast, CSOs are bundling the interests of people or groups who are not in a position to voice their concerns clearly enough. As an example, local residents in the vicinity of an airport would be unlikely to be heard one by one by the airport authority when another runway is being planned. But when residents join a local association they are much more likely to get their views across. From this very local stage the spectrum of CSO intervention goes up to where WWF or Greenpeace represent the interests not of people but of the natural environment. There is nothing new in this, with the exception perhaps of the scale of the issues, if we look at the long history of, for example, the Royal Society for the Prevention of Cruelty to Animals (RSPCA), which was founded in 1824 and is the oldest organization that represents “nature” – or beings that cannot speak for themselves.

The topic of CSO accountability has been revitalized with the recognition of the role they play in contributing to the implementation of the UN post-2015 Sustainable Development Goals (SDGs) together with the corporate sector. As the UN is using the term “non-governmental” for all that is not an official representation of the member states, the way in which UN agencies treat CSOs and businesses is deemed to be the same.

The involvement in the SDGs has a clear moral background, but the rules of the game have yet to be defined between CSOs, business firms and the UN agencies. Similarly, in the relations of non-governmental organizations (NGOs) with business firms, the backgrounds and the rules are very often undefined. One question is how a firm recognizes whether or not a group is worthy of entering into a dialogue with; another question is about the means that CSOs might use to gain attention. How to discern if a CSO is genuinely representing its intended beneficiaries and to what degree it is accountable has become a tricky question for business leaders and politicians (Slim 2002). How to deal with CSOs will be taken up in Chapter 7, which discusses stakeholder relations (section 7.5).

5.2 Ethics in government and public office

People who lead in the public sector need to achieve multiple and complex objectives. This multiplicity and complexity makes leading in the public domain very demanding and often fraught with ethical issues. Another field of concern is the relationship between business (i.e., business leaders) and the public domain (i.e., politicians), and raises questions of whether powerful corporations shape public policy, whether lobbying is a moral exercise, how far businesses must take part in developing regulatory frameworks, and similar questions. All of these questions look at the moral content of business activity with government and government authorities.

Despite decades of compliance efforts, the abuse of public office for private gain continues to flourish in local and state governments all over the world. But there are also outstanding examples of authorities that are successfully accomplishing moral conduct. This is not so much achieved by compliance rules, strict oversight and severe punishment for offenders but by exemplary leadership. Human centered management is essential for assuring that public officials behave morally; apart from setting examples, they need to influence the organization’s culture by defining the core principles that underlie how agency decisions are made at all levels of any government agency.

The core principles for morality in the public domain do not differ from those in the private domain: integrity, accountability, and trust and trustworthiness are ethical requirements for each officer in any institution. But trust is even more meaningful in the public domain, since public service is a public trust, and if there is anything unique about public service, it derives from this proposition. For a public administrator, upholding the public trust means faithfully executing one’s duties in support of the public interest and the collective good. From there, the first provision in the US Principles of Ethical Conduct for Government Officers and Employees (Office of Government Ethics 1992, p. 1) reads “Public service is a public trust, requiring employees to place loyalty to the Constitution, the laws and ethical principles above private gain.” As public officers spend public money, and they wield the power of the state in carrying out their role, they should be held to a higher standard than others, but public opinion often holds that government officials do not necessarily meet that higher standard (Lewis and Catron 1996; Leiserowitz et al. 2013). There is a lack of trust, a deficit in confidence.

The confidence deficit was also an issue in the context of the public-sector reforms that started in Europe at the end of the 20th century. They have all striven to overcome the confidence deficit, and ethical standards in public life have become a foremost political issue. Direct interest in this has been taken by the Organisation for Economic Co-operation and Development (OECD), whose Public Management (PUMA) department emphasized that a fourth “E” (for ethics) should be added to the reform triumvirate of economy, efficiency and effectiveness (OECD 1996). Research into the phenomenon by, among others, Bishop and Preston (2000) has revealed that the moral failures in government often derive not from willful misconduct (if we exclude blunt corruption) but from ignorance and the lack of capacity to cope with the complexity of government tasks. The source just quoted comes from Australia, where there may have been an overburdening of public officials with several new legislations coming forward at the same time, such as the Financial Management Standard of 1997, the Government Owned Corporations Act of 1993 and the Public-Sector Ethics Act of 1994 (Mackenroth 2004). Bishop and Preston show that requiring high standards of moral conduct by all public officials to be included in all decision-making processes does not come without a price, as it may raise complexity and slow down the procedures. There is, however, a compensating effect that comes with the advent of e-government, where Australia has become one of the leaders internationally (Guo and Lu 2004).¹

The confidence deficit may partly be due to moral dilemmas created for public servants, because the complexity of their duties may sometimes dictate contradictory actions. Moral imperatives for public service are very wide: “Not doing harm, easing or reducing injury, accounting for stakes and stakeholders, and taking care of the dependent and vulnerable” (Office of Government Ethics 1992, p. 5). As harm and injury claimed by one party to a dispute that a public authority has to settle may be completely the contrary from another stakeholder’s perspective, the public officer’s decision will necessarily disappoint one of them. This is just one type of quandary; public service encounters quite a few of them. It has been said that this is the fate of public servants since they have to deal with a society with unresolved value conflicts and moral ambivalence and they are “pulled this way and that in a ‘dilemmatic space’ of its own” (Hoggett 2005, p. 183).

The quandaries encountered by public service officials in fulfilling their wide-cast moral imperatives – their ethical dilemmas – may not be visible to a citizen or a business firm. What they notice are outcomes; they cannot see that the public official has to weigh care versus justice, individual claims versus the greater good, or consistency versus responsiveness. As with many issues in public administration, improvements in the dialogue with their counterparts would help the officials to acquire a better reputation. On the other hand, there is no way out of the twofold nature of public administration: it needs to restrict businesses (and citizens) through regulation that follows societal needs – for example, preventing practices that threaten health and asking for contribution to the maintenance of infrastructure. But, at the same time, the role of public administration is to enable business (and private) activities: markets can only function if they follow basic rules established by public authorities. It is from both aspects that ethical issues arise in the relationship between the public sector and businesses.

When government acts as a trustee of society (as in its role of defining rules and regulations), the relation to business, in many democracies, includes the process of hearings and consultations in the pre-legislative phase. This ensures that constituencies that are affected by a regulation get a voice and are respected before the regulation is passed – and it should also ensure that those who are affected will abide by the rule. But government also has a relationship with the business sector where both partners are mutually dependent on each other beyond the regulatory. Businesses expect governments to provide a profitable and stable economic environment, and governments expect businesses to provide taxes, jobs and investment. Behavior of one party that contradicts the other party’s expectation will produce damage; examples can be found in today’s political dilemma of managing the proper procedure towards renewable energy, where the German chancellor lost some of her acceptance by corporate leaders, or in the never-ending debate about US health insurance reform. From the ethical point of view, this context raises two questions: (1) Is it legitimate that business influences politicians (e.g., the broad-ranging lobbyism in the US)? (2) As the public sector is accountable to all members of society, to what extent must a government base its decision-making on both the common good and the long-term prospects for an industry, when both are impacted by rapid changes of policies (e.g., the brisk turn to heavily subsidized wind and solar energy in Germany)?

The main concern raised by the non-business sector in all countries of the world is the way in which business influences government through lobbying, as it is mostly private (no transparent public discussion) and uses direct access (no intermediation through corporative associations). Despite lobbying’s historical identification with the corruption of governmental processes, even the fiercest critics admit that it would be almost impossible to conduct public affairs without lobbyists (Fernandes 2009). From the practical side, lobbyists provide information to officials that they could not otherwise obtain; they bring and explain argumentation and they assist in identifying the consequences of proposed government action. Not only is it practical, in avoiding a bureaucratic apparatus to get that same information, but argumentation and advice also save taxpayers money. But lobbyists and lobbying are difficult to control.

From an ethical perspective, one would have to distinguish “good lobbying” from “bad lobbying.” The Woodstock Theological Center’s report on The Ethics of Lobbying has issued several principles, of which the first one is that “ the pursuit of lobbying must take into account the common good, not merely a particular client’s interest narrowly considered” (Woodstock Theological Center 2002, p. 84). But anyone who has ever acted as a lobbyist or has dealt with a lobbyist will agree that it is the common good (however defined) on which parties to a negotiation on a business or a public project would come to terms. While well intended, this principle will not deter the malevolent nor will it be able to monitor lobbying processes. There are approaches that serve the case a little better – morality, here, would need to be supported by laws.

A first legal device to control lobbyism at the federal level in the US was the Lobbying Disclosure Act of 1995, afterwards amended by the Honest Leadership and Open Government Act of 2007. And on January 21, 2009, President Barack Obama issued an Executive Order denying lobbyists employment in his administration. At the state level, there are laws and regulations covering everything from disclosure and reporting requirements to activities and conduct, and several jurisdictions have specific ethical guidelines and prohibitions on certain interactions between lobbyists and government employees (Rosenthal 2001). In the European Union there is no uniform regulation because every member nation has long-standing regulations for the relations between state and society. The original attempt by the European Commission was the issuance of a voluntary and self-regulatory code of conduct in 1992. The code set minimum standards only, as the Commission invited lobbyists to adopt their own codes on this basis. Only a few responded, with the most prominent being the code adopted by the Society of European Affairs Professionals (SEPA), of which the basic principles are as follows (Society of European Affairs Professionals 2007):

In their dealings with the EU Institutions, European Affairs Professionals shall:

• State their identity (name and organization);
• Declare the interest represented;
• Neither intentionally misrepresent their status for the nature of their inquiries to officials of the EU Institutions nor create any false impression in relation thereto;
• Honor confidential information and embargoes;
• Not disseminate false or misleading information knowingly or recklessly and exercise proper care to avoid doing so inadvertently;
• Not sell for profit to third parties copies of documents obtained from EU Institutions;
• Not obtain any information from European Institutions by illicit or dishonest means;
• Avoid any professional conflicts of interests;
• Neither directly nor indirectly offer nor give any financial inducement to any EU official, nor any member of the European Parliament, nor their staff;
• Not exert any improper influence on public servants;
• Only employ EU personnel subject to the rules, and registration and confidentiality requirements of the EU Institutions.

Even though the SEPA code is drafted in general terms, the strict self-discipline which it demands and its internal sanction mechanisms fulfill the major purpose of providing transparency (Coen and Richardson 2009).

The Commission, dissatisfied with the low response to the call for voluntary obligation, launched a Green Paper on a European Transparency Initiative in 2006, with the process of delivering a pertinent EU Directive still going on. For their part, a coalition of CSOs grouped under the ALTER-EU alliance (Alliance for Lobby Transparency and Ethics Regulation) has signaled its readiness to apply a code of ethics applicable to all lobbyists across the board, including its members; it also calls for mandatory registration. Registration is already in force in the European Parliament, which has an accreditation system for all persons needing frequent access to this institution. The system regulates physical access to the Parliament. The quaestors issue special passes that are valid for one year, stating the holder’s name, the name of the firm that employs the holder and the organization the holder represents. A register of accredited lobbyists is published on the Parliament’s website.

Ethical considerations of lobbyism must have in mind that effective lobbyists are experts who are well versed in the legislative process and have political acumen that enables them to identify opposition coalitions and sources of support. They will apply these skills to achieve favorable results for their clients. This capability and competency must be met by the counterparts in the legislature and the public administration, and it is there where efforts also have to be made to educate office holders.

To end this section on ethical issues in public institutions, a quick look will be taken at a study carried out on Regulating Conflicts of Interest for Holders of Public Office in the European Union (Demmke et al. 2007), concurring with the subject just discussed. The study shows that reform processes are under way internationally that lead to new perceptions and procedural innovations in conflict of interest situations for public office holders. The trend is moving towards more disclosure requirements in registers and the setting up of new independent ethics committees and other monitoring bodies. However, the authors are afraid that there may still be an ethical deficit. As one single violation by only one public office holder may be sufficient to cast public doubt on the integrity of the whole class of office holders and the whole institution, public office holders must constantly be reminded of their specific public responsibility. And the authors continue:

They also state that uniformity throughout the whole of the EU is not a means to achieve the goal, and they recommend that ethics regimes be carefully designed to fit the relevant institutional system, its structures, processes, resources, culture and tradition.

As per Demmke et al.’s report, it is implementation and taking account of cultural differences that will fulfill the requirements for and the expectations on human centered management. This also applies to the business sector, as will be set out in the next chapter.