Ethics and compliance are often perceived as a form of protection for an organization. That framing is just one part of the picture.

Instead, organizations should view strong ethical culture as a value-creating asset. Culture can build trust, improve decision quality, strengthen business relationships, and allow an organization to perform with consistency—at all times and especially during times of uncertainty and when pressure is high.

Ethical leadership pairs tone at the top with practices that embed ethical values and conduct throughout an organization. When ethics are woven into culture and cascaded through the enterprise—from the CEO to the C-suite to managers—employees understand leadership’s ethical expectations. This transcends policy language. When people understand that integrity is expected at all times, they tend to make more confident, more consistent choices across countless daily decisions.

Michael Rossen

A business case for trust

Ethical leadership works to create trust among stakeholders. An absence of such leadership can permit ethical lapses that can lead to an immediate and dramatic loss of trust.

The stakes of trust loss are high. A Deloitte Canada Human Experience TrustID Survey found that companies with reputations for trustworthiness can outperform peers in market value by a factor of four, and that 88 percent of customers will return to buy from a brand they trust. And in a separate report from Deloitte Global, “How boards are nurturing and measuring stakeholder trust,” 81 percent of surveyed board members and C-suite executives said trust directly affects their business relationships.

This gives ethics and compliance professionals a sturdy frame to place around their work, presenting ethical culture as a performance lever that can enrich durable stakeholder relationships—with clients or customers, regulators, investors, and employees.

To embed ethical leadership in day-to-day operations, organizations can turn to Deloitte’s actionable framework, the four E’s of Ethical Leadership (Expression, Engagement, Empowerment, and Evaluation). These four elements work as an operating system, each reinforcing the others and together underpinning an ethical culture that can contribute to organizational health and long-term success.

The Four E’s of Ethical Leadership

Expression: Shaping culture through values

Ethics Expression is an organizational approach in which values and ethical standards are communicated clearly—what is expected, how values are upheld, and how the organization will respond to missed expectations.

How it creates value: Clear, consistent ethics messaging makes ethical behavior the norm and discourages unethical actions. It can also accelerate decision-making by reducing ambiguity. Note that cadence matters in messaging. Consistent, frequent delivery can help improve retention and demonstrate commitment.

To embed Expression, consider:

  • Cascading messages through the leadership chain. In ethical leadership, the CEO sets the tone; the C-suite amplifies it; managers and other leaders instill it in employees. Provide leader-ready assets, such as conversation guides, to reinforce standards in day-to-day moments.
  • Using multiple forums to meet people where they are. Effective Expression happens in abundance, at all-hands meetings and town halls, organization-wide communications, leader discussions and presentations, and elsewhere.
  • Making the headline unmistakable. The message should be that integrity matters as much as business outcomes and that it is everyone’s responsibility.

Engagement: Learning to put integrity first

Ethics Engagement is continual learning and training programming that gives employees tools to make decisions that place integrity first and protect themselves, their colleagues, and the organization.

How it creates value: Engagement bolsters decision quality at scale. When employees understand ethical implications, they can navigate complex situations more effectively and act in the best interest of stakeholders. Engagement also can support regulatory compliance and enable faster, more coordinated responses when lapses happen, because people know the rules and what to do.

To embed Engagement, consider:

  • Starting on day one, with routine reinforcement. Learning should happen regularly at all levels, with expectations established immediately for new hires and reinforced through periodic refreshers. Anyone promoted or transferred may need additional learning to match their new responsibilities and risk exposure.
  • Being timely and authentic. Effective training brings to life relevant, realistic dilemmas and highlights new and emerging ethical risks.
  • Building ethics into how work is delivered. Incorporate ethical considerations into project design, implementation, and project debriefs. This prompts teams to routinely look beyond the immediate situation and consider the broader picture of personal and organizational reputation.

Empowerment: Creating a speak-up environment

Ethics Empowerment is an environment in which employees are encouraged and enabled to speak up and consult freely on ethical dilemmas.

How it creates value: Empowerment strengthens organizational resilience. When people can surface concerns early, leaders can respond earlier and more effectively, helping mitigate potential ethical risk. Empowerment also reinforces trust internally because employees see that values are real, supported, and protected.

To embed Empowerment, consider:

  • Offering multiple, safe reporting and consultation channels. Provide and socialize options inclusive of speaking to a supervisor, manager, or other leader; connecting with talent or ethics teams; and using a helpline that allows anonymous reporting. Multiple paths make it easier for employees to choose an approach that fits the situation.
  • Centering values and the code of conduct to build confidence. Reinforce that employees can speak up without fear of retaliation by codifying expectations in policy and corporate identity statements.
  • Treating speak-up pathways as part of culture-building. Demonstrate that integrity is supported in practice through storytelling that highlights ethical wins and lessons learned.

Evaluation: Measuring ethics program effectiveness

Ethics Evaluation is gauging how ethical leadership and culture are performing across an organization.

How it creates value: The ethics landscape is constantly changing. Evaluation ensures the focus of ethical leadership and culture stays relevant, identifies what is working, and helps organizations respond to emerging trends and risks. It also signals that leadership understands the ethical challenges the organization and workforce faces—an important trust-builder that reinforces tone at the top.

To embed Evaluation, consider:

  • Periodically weighing whether efforts are resonating. Use structured assessments, inclusive of pulse surveys and internal focus groups, to gather feedback and improve communication effectiveness. Also consider benchmarking ethics initiatives against leading practices.
  • Keeping pace with risks—or staying ahead of them. Engage in risk-sensing activities to identify emerging trends and use the insights to evolve programming proactively.
  • Reinforcing ethical leadership through performance management and celebration. Spotlight employees who took a stand to advance integrity and embed ethical leadership in performance management criteria.

How the 4 E’s sustain culture

The most sustainable ethical cultures treat the 4 E’s as an operating system. Expression sets expectations and normalizes integrity. Engagement equips people to act. Empowerment ensures that concerns and questions surface early. Evaluation keeps the system current and credible—and, importantly, feeds learning back into the next wave of Expression.

When these practices are executed consistently, ethical culture becomes a trust engine that helps strengthen stakeholder relationships and support long-term organizational health and success.


Michael Rossen is a managing director in Deloitte’s US Ethics Office. He leads organization-wide initiatives to strengthen an ethical culture and reinforce commitment to integrity, trust, and quality. In his 25 years at the organization, Michael has advised clients on ethics and compliance, culture, risk, forensic investigations, crisis management, and corporate governance. Michael is a Certified Public Accountant (CPA) and holds the following credentials: Certified in Financial Forensics (CFF), Chartered Global Management Accountant (CGMA), and Leadership Professional in Ethics & Compliance (LPEC).