Opinion on the cause of bad behavior in organizations can range between two extremes. The first is that there are people who are inherently bad and cannot be changed. The second is that people need good influences to guide them to do the right thing. Like most things in life, the truth is somewhere in between. Even the best compliance programs cannot always prevent rogue employees from breaking the rules
Still, while bad apples are a fact of life, it has become less credible as an excuse for harmful corporate behavior. Not only do regulators wonder why a compliance system failed, but why was it not detected sooner and/or allowed to continue as long as it did. Is it realistic to believe that a single employee could create a slush fund for the payment of bribes in an FCPA case, or that it was only a few engineers at Volkswagen who masterminded and implemented fraudulent emissions testing?
