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acts within the letter of 
the law
, and that violations are prevented, detected and punished. Some organisations, faced with the 
legal consequences of unethical behaviour, take legal precautions such as those below. 

Compliance procedures to detect misconduct 

Audits 
of 
contracts 

Systems for employees to report criminal misconduct without fear of retribution 

Disciplinary procedures to deal with transgressions 
4.4.2 Integrity-based programmes 
An integrity-based approach combines a concern for the law with an 
emphasis on managerial 
responsibility
for ethical behaviour. Integrity strategies strive to define companies' guiding values, 
aspirations and patterns of thought and conduct. When integrated into the day-to-day operations of an 
organisation, such strategies can help prevent damaging ethical lapses, while tapping into powerful 
human impulses for moral thought and action. 
Whistleblowing
is the disclosure by an employee of illegal, immoral or illegitimate practices on the part 
of the organisation. This may appear to be in the public interest, but confidentiality is very important in 
the accountants' code of ethics. Whistleblowing frequently involves 
financial loss
for the whistleblower. 
(a) 
Whistleblowers may lose their jobs. 
(b) 
A whistleblower who is a member of a professional body cannot, sadly, rely on that body to take 
a significant interest, or even offer a sympathetic ear. Some professional bodies have narrow 
interpretations of what is meant by ethical conduct. For many, the duties of 
commercial 
confidentiality
are felt to be more important. 
 EXAM FOCUS POINT 
The ethics codes described above can be related to mission, culture and control strategies. A 
compliance-based approach suggests that bureaucratic control is necessary; an integrity-based 
approach relies on cultural control.
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CHAPTER 19
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ETHICAL CONSIDERATIONS