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The key element of corporate governance here would be corporate culture. Culture is the generally accepted set of expected behavior within the corporation. It is generally the result of the actions (intended and unintended consequences) of the CEO. It is rare that cultural change can be driven by anyone else because it must be built into every aspect to corporate governance, including the rewards systems put in place from the top down.

Companies that tell employees to "make your numbers, whatever it takes" are at great danger of promoting people who put ethics and moral reasoning behind making the numbers look good. Companies that recognize employees for "doing the right thing" and who routinely expect total integrity from their people more typically get ethical decisions from every person in the organization.

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