420 Global Ethics for Leadership
the gift not OK? If the gift is not OK, then the organization faces the
question of what to do about non-compliant behaviour.
There is a certain appealing simplicity to viewing ethical conduct in
international organizations as the sole province of rules. Unfortunately,
as any manager has concluded, human behaviour is rarely sufficiently
straightforward to permit the binary application of compliance rules. In
our gift example, what if the gift is an offer of home hospitality? A dis-
counted ticket to the opera? A used and still beautiful objet d’art? We
can imagine numerous gift scenarios where the item offered may or may
not be tangible, and may or may not be easily marketable. How then can
the absolute rigor of the hypothetical rule on gifts be applied equitably
and predictably? Even this simple example quickly breaks down in the
face of differential application.
Human behaviour is not simple and rarely binary. As business ethi-
cists have learned, compliance rules can support an organizational cul-
ture solidly informed by ethical virtues and behavioural expectations.
But rules per se will not create an ethical culture.^326 Where rules are
explicitly based on ethical principles that appeal to virtuous conduct,
staff are more likely to conform their behaviour because they see the
direct connection between compliance and virtue. It may be as simple as
explaining why certain behaviour is expected.
There is one more situation where an appeal to values—not rules—is
ultimately beneficial. And that is in time of crisis. When decisions be-
come urgent and time becomes short, when the stakes for human life and
property are stark, and the likelihood of harm is high, decision-makers
need values. When an urgent decision needs to be made, it is the rare
international civil servant who calls for a “time out” to consult the mul-
tiple expressions of regulations and rules that may or may not apply.
326
See also: Killingsworth, S., “Modeling the Message: Communicating Com-
pliance through Organizational Values and Culture,” 25 The Georgetown Jour-
nal of Legal Ethics 961.