The Integrity of Integrity Programs: Toward a Normative Framework

Abstract

Most of the norms developed for integrity programs are grounded in positivist arguments focused on effectiveness. The norms developed in this article are grounded in normative arguments that are directly deduced from the concept of integrity itself. The four norms are intentional wholeness; organizational wholeness; societal wholeness; and processual wholeness. These norms are operationalized into subnorms and indicators, resulting in a normative framework that helps to assess and advance the integrity of integrity programs.

Keywords:

• integrity framework
• integrity management
• integrity program
• wholeness

To embed and advance integrity, organizations can design and implement an integrity program. Following Kaptein (2009), an integrity program may be defined as the formal organizational control system designed to create a culture of integrity, to impede integrity violations, and to promote integrity behavior. Integrity programs (henceforth: IPs) may be composed of a variety of measures, such as a code of conduct; an integrity office(r); integrity training; whistleblowing procedures; trusted persons; investigative and corrective policies for misconduct; and pre-employment screening (Ferrel, LeClair, & Ferrel, 1998; Hoekstra & Talsma, 2019; Kaptein, 2015; MacLean, Litzky, & Holderness, 2015; Weber & Wasieleski, 2013). As IPs have become commonplace in both the public and private sectors (De Graaf & Macaulay, 2014; Huberts, 2018; Menzel, 2015), research on their content, use, and quality has expanded considerably.

Research on the quality of IPs is mostly based on a positivist approach that determines the quality of an IP by the extent to which it is effective in practice. For example, Treviño and Weaver (2003) assess the quality of such programs in relation to the improvement of employee behavior, while Kaptein (2009) looks at the improvement of the organizational culture. An advantage of this way of assessing the quality of IPs is that it makes clear their benefit. Furthermore, this approach is evidence based and thus convincing because it is based on what works and what makes the program effective.

A positivist approach to develop norms for IPs has limitations. This approach requires extensive empirical research because assessing the effectiveness of specific norms is complex (Kaptein, 2015). For example, the effectiveness of codes may be influenced by many factors, each of which is difficult to measure, and contingencies have to be filtered out. As such, a decrease in fraud committed by employees would not necessarily be due to the implementation or improvement of the code; it could also be due to changes in the societal and economic environment of the organization.

Instead of a positivist approach, some scholars have opted for a normative approach to develop norms for IPs. The quality of IPs is then based on the extent to which they satisfy norms that are derived from a concept of what is “good.” For instance, Schwartz (2002) grounds the norms for the quality of a code (which is one component of an IP) on a set of universal moral values like respect, caring, and citizenship. Reynolds and Bowie (2004) base their norms on Kantian ethics, and argue, for instance, that employees should be able to follow the program from their own free will. An advantage of this normative approach is that developing the norms for an integrity program would not require extensive empirical research, because the process is based on moral reasoning. However, a disadvantage of this approach is that because it derives the norms from external sources (whether universal values or Kantian moral philosophy), the norms will not be supported unless the relevant source is. To make a stronger case for a normative approach, this article proposes not to derive norms for IPs from external sources but from an internal one; that is, the concept of integrity itself. Faithfulness to the concept of integrity results in more direct and better-fitting norms. Moreover, because an IP by definition stands for integrity, it should therefore inherently possess integrity.

Based on this idea, this article directly deduces integrity norms for IPs from the concept of integrity itself. The word “integrity” originates from the Latin integritas, and refers to a state of wholeness, as in being complete, unbroken, united, and entire (e.g., Cox, La Caze, & Levine, 2014; Hartman, Wolfe, & Werhane, 2008; Heywood, Marquette, Peiffer, & Zúñiga, 2017). Wholeness as such can be regarded as an elementary and overarching notion of integrity. This focus on wholeness, as either a direct or indirect notion of integrity, also seems to be dominant in literature reviews on integrity (Montefiore, 1999; Robinson, Cadzow, & Kirby, 2018). From this concept of integrity as wholeness, the following four norms for IPs are deduced: intentional wholeness; organizational wholeness; societal wholeness; and processual wholeness. Each of these norms is operationalized into three subnorms and six indicators, which results in an evaluative framework for assessing and advancing the integrity of IPs.

DISTILLING INTEGRITY NORMS FOR IPS

In this section, the four norms and their underlying subnorms are introduced and attributed to IPs. To begin, wholeness implies that something actually is what it seems (and what it is expected) to be. This is wholeness as authenticity: something should be real and right in its core, clear in what it is, and not easily be mistaken for something else. Accordingly, the first norm is intentional wholeness, which means that those who are in charge of the IP (i.e., top management because they bear the final responsibility for organizational integrity) should have pure and intrinsic motivations, and they support the IP in the course of time.

Wholeness also entails internal coherence: the parts match together well and they are organized as an entity. Thus, the second norm is organizational wholeness, which means that the integrity measures of an IP are organized as one, and that the IP is one with the organization. The latter implies that the IP is customized to the specifics of and is integrated in the organization.

Wholeness furthermore entails correspondence with the external context. This implies contextual embeddedness, which ensures that something will make sense and be acceptable for relevant others. Given this, the third norm is societal wholeness, which means that IPs should also reflect the societal moral values concerning organizational integrity. In other words, the wholeness of an IP is not limited to organizational boundaries. Involvement of and communication with society and stakeholders are aspects of societal wholeness.

Finally, wholeness implies the capacity to change, develop, and renew to remain whole in the course of time. This is the reason that wholeness does not refer to a (single) static situation but rather to a (permanent) dynamic process. Consequently, the fourth norm is processual wholeness, which entails the subsequent planning, implementation, and improvement of IPs. As organizational circumstances may constantly change, accomplishing organizational integrity requires that IPs have the capacity to adjust to these changes. The three process phases of an IP (i.e., planning, implementation, and improvement) have to be executed completely and repetitively.

SPECIFYING AND UNDERPINNING INTEGRITY NORMS FOR IPS

This section specifies and underpins the abovementioned norms derived from the concept of integrity. Each norm is operationalized with three subnorms, which, in turn, will have two indicators each. The resulting framework is presented in Table 1.

TABLE 1. Framework for the Integrity of Integrity Programs.

Norms	Subnorms	Indicators
1. Intentional Wholeness	1.1 IP motivation	1.1.1 The IP is adopted by management for reasons of ethical responsibility. 1.1.2 The IP is used by management to stimulate employees’ integrity.
	1.2 IP support	1.2.1 The IP is led and supported by management through role-modeling behavior. 1.2.2 The IP receives adequate resources from management to be realizable.
	1.3 IP constancy	1.3.1 The IP is acknowledged by management as a long-term responsibility. 1.3.2 The IP functioning is ensured by management to be resistant to organizational difficulties.
2. Organizational Wholeness	2.1 IP customization	2.1.1 The IP content addresses the organizational integrity risks and dilemmas. 2.1.2 The IP is specifically designed for the organization.
	2.2 IP coherence	2.2.1 The IP measures are complete. 2.2.2 The IP measures are interconnected.
	2.3 IP integration	2.3.1 The IP incorporates the knowledge and experiences of employees. 2.3.2 The IP is paired with adjacent organizational programs and functions.
3. Societal Wholeness	3.1 IP responsiveness	3.1.1 The IP reflects societal moral values, relevant laws, and regulations. 3.1.2 The IP reflects the expectations of external stakeholders.
	3.2 IP cooperation	3.2.1 The IP involves stakeholders in the IP development. 3.2.2 The IP involves stakeholders in the IP implementation.
	3.3 IP accountability	3.3.1 The IP and how it is developed is communicated externally. 3.3.2 The IP results are communicated externally.
4. Processual Wholeness	4.1 IP planning	4.1.1 The IP is based on a plan that consists of clear ambitions and targets. 4.1.2 The IP is based on a plan that describes the implementation and improvement processes.
	4.2 IP implementation	4.2.1 The IP measures are well developed. 4.2.2 The IP measures are well introduced in the organization.
	4.3 IP improvement	4.3.1 The IP is periodically monitored and evaluated. 4.3.2 The IP is regularly adapted.

Intentional Wholeness

The first norm for IPs is intentional wholeness. This refers to the requirement that top management uses the IP for what it represents, and that the IP is not misused for other purposes. This is in line with Heywood and colleagues (2017), who argue that integrity implies a deliberate motivation to do the “right thing” for the “right reason.” Moreover, integrity entails having pure, dedicated, and sincere intentions (Weber & Wasieleski, 2013). In addition, management should actually support IPs as a long-term responsibility. Given these, three subnorms constitute intentional wholeness, namely, IP motivation, IP support, and IP constancy.

IP motivation (1.1) refers to the moral drives and ideals underlying the integrity program and to the fact that the IP is actually used for what it is meant: to support employees’ integrity. Firstly, IP motivation necessitates (1.1.1) that the motives for adopting the program are based on certain moral ideals, ambitions, and responsibilities (cf. Weber & Wasieleski, 2013) and thus on the realization of worthwhile, desirable, and moral principles (Brown, 2005; Maak, 2008). In other words, the motive for IP development should at least be intrinsic (i.e., because it is good in itself) and not only extrinsic (i.e., because it is worthwhile for other reasons; for instance, to lower the risks of legal fines or to avert reputational damage). Extrinsic motives are permitted, but an IP that is only motivated by extrinsic motives and lacks intrinsic motives is not morally motivated. Secondly, (1.1.2), IP motivation implies that management should adopt the IP with intention to actually provide guidance for employees’ integrity, because employees are the primary object of the IP. This is in line with Valentine and Fleischman (2007), who maintain that IPs should essentially focus on enabling employees to work from a moral standpoint. In short, it can be argued that an IP has integrity when management adopts the IP because of ethical ideals and uses it with the intention to boost and safeguard employees’ integrity.

IP support (1.2) refers to the unity between management’s motivation for the IP and their actual backing of the program, both visibly and materially. IP support can be understood as loyalty to the program by acting according to it. IP support entails, in the first place (1.2.1), management demonstrating role-modeling behavior to show that they lead the integrity program (Kaptein & Wempe, 2002), as well as emphasizing the program’s importance. This is crucial: management is at the center of ethical activity, and employees are watching and reading their words, intentions, and actions (Dobel, 2018). IP support also entails the (1.2.2) provision of adequate resources by management for the program to be realizable. Hoekstra and Kaptein (2012) explain that next to adequate budget, ascribed authority, and time, organizations also need to employ experts to run the IP. Without such resources, an IP does not seem to make much sense (Wood, 2002). An annual (earmarked) IP budget may be considered because it would prevent the IP from becoming a residual budgetary item. Moreover, doing so avoids integrity officers’ becoming too dependent on the willingness of other departments to contribute financially. This dependence could lead to the unfortunate situation where the IP’s content would be determined by what others are willing to finance instead of by what is necessary for the organization. In short, an IP possesses integrity when management is actually committed to lead the IP and provides the necessary resources to run it.

IP constancy (1.3) refers to management’s unbroken attention for the integrity program. Although many other everyday organizational issues easily tend to overshadow the concern for integrity and integrity management, Kaptein and Wempe (2002) stress that integrity is not a luxury good, and requires constant care and attention. Therefore, IP constancy (1.3.1) requires that management should acknowledge the pursuit of integrity as a long-term responsibility, especially during difficult times, when the stakes are high or when the consequences may be unpleasant (McFall, 1987; Rees & Webber, 2014). Examples of such times are when there is pressure to meet certain targets, when the IP budget is low because of austerity measures and budget cuts, or when the time to pay attention to integrity is limited because of organizational restructuring (Dobel, 2018; Hoekstra, 2016). Thus, IP constancy also demands (1.3.2) that management should be resistant to organizational difficulties that might impair the integrity program. IPs that are easily suppressed by everyday issues or difficulties are not sustainable. Such IPs may invoke cynicism and distrust regarding management’s intentions and commitment, and send the message that integrity is considered less important than is claimed (Brenner, 1992). In short, an IP possesses integrity when management demonstrates a long-term commitment to it, irrespective of organizational difficulties.

Organizational Wholeness

The second norm for IPs is organizational wholeness, which means that the measures of an IP are organized as one, and that the IP is one with the organization. More specifically, this means that the IP is attuned to the specific organizational conditions and circumstances, that the integrity measures are complete and interconnected, and that the program relates to both employees and other organizational policies. Accordingly, the following three subnorms pertain to organizational wholeness: IP customization, IP coherence, and IP integration.

IP customization (2.1) refers to the fit between the specific challenges to organizational integrity and the content of the integrity program. IP customization requires firstly (2.1.1) the identification of the integrity-related risks and dilemmas of the organization, because this is crucial for determining the IP’s content. Risk assessment can be used to determine the vulnerable processes of the organizations (Maak, 2008), and dilemma sessions can be used to explore and discuss the integrity-related problems and pitfalls employees may encounter in their day-to-day work (Kaptein, 1999). Secondly, IP customization requires (2.1.2) that the IP should be specifically designed for the concerned organization (cf. Dobel, 1999), instead of being adopted directly from other organizations or copied and pasted from generic blueprints. Pritchett, Woolcock, and Andrews (2010) call these copy-paste practices isomorphic mimicry. Such imitated-IP approaches should be avoided, because the IP being copied may not adequately match, and thus will not be one, with the organization. In short, an IP has integrity when it is specifically designed for the organization, and is attuned to the particular challenges of organizational integrity.

IP coherence (2.2) refers to the completeness of the integrity program and the interconnection of its constitutive measures. In the first place, IP coherence entails (2.2.1) the completeness of the integrity program: that is, all the necessary integrity measures are in place. When a crucial measure is missing (e.g., an integrity code or an integrity reporting line), then the IP is less complete, by making it less coherent as a whole and therefore, of lower quality. Within this normative framework, the content of the necessary integrity measures is determined by the requirements of the organization (see 2.1) and by a country’s legal framework and requirements (see 3.1). Thus, the specific situation determines what the necessary instruments are. In the second place, IP coherence entails (2.2.2) the interconnectedness of the incorporated integrity measures. This means that the integrity measures should unite and reinforce each other. Coherence among the different integrity measures can be realized, for instance, by making clear the respective functions of each of the components and by reference between and among the integrity instruments (Hoekstra & Kaptein, 2020). A specific example would be referring to the integrity officer and integrity reporting procedures in an integrity code. The combination of integrity measures is considered to be more than the sum of the individual measures (cf. Brenner, 1992), because the combination creates synergy (MacLean & Behnam, 2010). In short, an IP has integrity when it is complete in terms of incorporated measures and when these measures are coherent.

IP integration (2.3) refers to the use of employees’ input in the development and design of the IP and to the extent to which the IP is related to other organizational plans, processes, and policies. IP integration (2.3.1) involves the incorporation of employees’ knowledge and experience in the integrity program. As members of the organization, employees’ input is considered valuable for the IP. IPs that are simply handed down as an order from headquarters lack connection (wholeness) with the workforce (Kaptein & Wempe, 2002; Wood, 2002). However, it may not be practical to involve all employees in this process. A pragmatic solution could be to make a selection of employees; for instance, through the involvement of the work or labor council. IP integration also involves (2.3.2) pairing the program with adjacent organizational programs and functions. Integrity is a multidisciplinary policy area (Huberts, 2014) that is shaped by many different functionaries and departments with different perspectives (Maesschalck & Bertok, 2009; Rossouw & Van Vuuren, 2004). Integration with human resources; finance; legal; communication; security; information technology; and audit policies and programs is recommended (Hoekstra, 2016). A well-integrated IP that is paired with and supported by other organizational policies, programs, and disciplines can be considered whole. To conclude, an IP possesses integrity when it integrates employees’ input and when it is paired with adjacent organizational policies and programs.

Societal Wholeness

The third norm for IPs is societal wholeness, which means that IPs should reflect (align with) the societal values concerning organizational integrity. As integrity is a social and relational quality that is subject to a wider evaluative community (Brown, 2005; Calhoun, 1995; Reynolds & Bowie, 2004), an organization cannot independently define its own integrity. Instead, organizations should be responsive to the integrity expectations of others. Next to this, two aspects of societal wholeness are the involvement of external stakeholders in the IP and the preparedness of top management to assume public responsibility for the IP. Accordingly, three subnorms substantiate this third criterion: IP responsiveness, IP cooperation, and IP accountability.

IP responsiveness (3.1) refers to the fit between the IP and the moral expectations of society in general and of stakeholders in particular. The word “moral” is crucial here, because it excludes immoral or ethically questionable expectations or values. Given this, IP responsiveness necessitates (3.1.1) that the program reflects societal moral values. This includes compliance with relevant laws and sectorial regulations, practices, and standards (Wulf, 2012). IP responsiveness also involves (3.1.2) consideration of the expectations of the organization’s relevant external stakeholders (Maesschalck & Bertok, 2009). Stakeholder analysis is a method that can be used to identify stakeholders and their expectations (Mitchell, Agle, & Wood, 1997). In conclusion, an IP has integrity when it reflects the moral values of society and adheres to the expectations of external stakeholders.

IP cooperation (3.2) entails the active involvement of identified external stakeholders in the design and implementation of the integrity program. IP cooperation requires (3.2.1) that stakeholders be involved in the actual development of the integrity program. This involvement contributes to the unity of the IP content with the external expectations, and is often based on what is called “stakeholder dialogue”: only in such a socially oriented dialogue can the organization completely fulfill its integrity-management duties. Stakeholder involvement also creates feelings of co-ownership, responsibility, and acceptability. IP cooperation also requires (3.2.2) the involvement of external stakeholders in the implementation of integrity programs. This entails the proper introduction of the IP to stakeholders and their familiarization with the developed integrity measures. For instance, it is crucial for integrity codes that contractors understand the reason that the code is introduced, what it expects of them (e.g., regarding the offering of gifts to employees), and what the consequences are for code violations (e.g., future exclusion from service purchases). To summarize, an IP has integrity when external stakeholders are actively involved in its development and implementation.

IP accountability (3.3) entails the preparedness to explain openly and honestly how the organization fosters integrity via its IP and with what results. This is a matter of social responsibility, because the organization is part of a larger community, and thus has to take into account the interests of stakeholders. IP accountability entails (3.3.1) an organization that is communicative (open and transparent) about its developed IP. Regular communication makes an organization’s approach to its responsibilities transparent and better understandable. IP accountability also necessitates (3.3.2) the organization’s preparedness to communicate about the performance, progress, and failures of its IP. Communications about the IP should not be used as a “selling device” but as an instrument for authentic representation and stakeholder dialogue (Maak, 2008). This also signifies the organization’s willingness to improve the IP. To summarize, an IP has integrity when communicated, because this unifies the organization with its external environment.

Processual Wholeness

The fourth norm for IPs is processual wholeness, which involves designing IPs as permanent and dynamic processes. As organizational circumstances can change, accomplishing organizational integrity involves the capacity to respond to changes (Cox, La Caze, & Levine, 2003). Therefore, the pursuit of integrity is as a never-ending process (Kaptein, 1998). Processual wholeness entails the repetitive execution of the different process phases that comprise an IP (i.e., planning, implementation, and improvement). This ensures that the IP will be adaptive, and enables the IP to remain whole in the course of time. Below are descriptions of the three process phases as subnorms for IPs.

IP planning (4.1) entails ambitions regarding the integrity program to be further specified and amplified into corresponding targets. IP planning is the preparatory phase and sees to the concretization and realization of the program. IP planning is a matter of wholeness, because it connects ambitions to concrete targets and outcomes. Without a clear plan and set targets, integrity activities are destined to remain rather incident-driven (Van Der Wal, Graycar, & Kelly, 2016), prompted by scandals (Heywood, 2012), or impelled by erratic political or financial decisions (Lawton, Rayner, & Lasthuizen, 2013). Thus, as a matter of wholeness, IP planning entails firstly (4.1.1) specifying the program’s ambitions and targets in a plan. As Joseph (2002) points out, without a well-considered and well-planned approach, it may be difficult to keep the IP focused. This plan, sometimes referred to as integrity plan (cf. Hoekstra, 2016; Hoekstra & Kaptein, 2012;), is a document that also provides clear direction for the realization of the entire cycle of the IP process. Secondly, IP planning requires (4.1.2) clarity regarding how to carry out the following implementation and improvement phases. An integrity plan is considered a powerful tool—once established, it will prevent deterioration of integrity-related ambitions. In short, an IP has integrity when it is based on clear ambitions and targets and contains a plan for its implementation and improvement.

IP implementation (4.2) refers to the actual development and introduction of integrity measures in the organization. Implementation reflects the adage “walk the talk,” as in meet created expectations. When announced IPs are not actually implemented, there is a disconnection between the talk and the walk. Khaled and Gond (2015) calls this organizational hypocrisy. IP implementation entails firstly (4.2.1) the development of integrity measures. Without such measures, the IP is empty and thus not whole. The development sequence may vary, depending on the organization’s most pressing needs and eventual budget and time constraints (Kaptein, 2015). IP implementation also implies (4.2.2) that integrity measures are properly introduced and embedded in the organization. This necessitates familiarizing employees with the developed integrity measures. For instance, it is crucial for integrity codes that employees understand the reason that the code is introduced; where it can be found; what it practically prescribes; what sort of behavior it requires; and what the consequences are of violations. Middle management, especially the personnel of which are responsible for introducing and applying the integrity instruments in their respective departments, play an important role in this regard (Kaptein, 1998). Moreover, integrity instruments that are decoupled from the day-to-day work processes may be considered as mere window dressing (MacLean et al., 2015), because they will fail to contribute to the IP. Thus, an IP has integrity when its measures are developed and introduced in the organization.

IP improvement (4.3) refers to the periodical analysis and adaptation of the integrity program. IP improvement entails (4.3.1) periodical monitoring and evaluation of the integrity program. This makes it possible to assess the implementation process and the extent to which the intended ambitions and objectives are realized. Periodical analysis also enables organizational learning, which is crucial for the adaptation (4.3.2) of the IP (Weber & Wasieleski, 2013). Joseph (2002) points out that as IPs are often developed in times of crises and thus hastily, they are not likely to suit long-term organizational needs. To remain current, the IP has to evolve and change along with the organization. Updates and revisions ensure that the program demonstrates wholeness with regard to all developments inside and outside the organization. New themes, like the use of social media by individual employees (Hoekstra & Van Dijk, 2016), the #MeToo discussion, and the ethical issues of big data and biased algorithms (Jurkiewicz, 2018), need attention and may require IP adaptation. All these themes provide new input for the planning phase, which makes the process circular and ensures permanent improvement of the IP. The IP is thus ideally a process that evolves based on experience and continuous adjustment (Hoekstra & Kaptein, 2012; Weber & Wasieleski, 2013). In sum, an IP has integrity when it is regularly analyzed and adapted.

DISCUSSION AND IMPLICATIONS

In this final section, some issues and implications of the developed framework are discussed. These issues concern the wholeness and misuse of the framework; possible tensions within the framework; how the normative framework relates to effectiveness; and the framework’s relevance for the ethics literature.

Concerning the framework’s wholeness and misuse; given that integrity stands for wholeness, each of the developed norms is necessary for IP integrity. This implies that to the extent that norms are lacking, the IP is fractioned, its integrity impaired. This is consistent with the notion that integrity is a gradual rather than an absolute construct (Kaptein, 2018). Formulated positively, this means that an IP that meets more of the developed norms scores higher on the wholeness continuum and thereby in integrity. A related question is whether an IP that lacks integrity excuses employees for their own lack of integrity. This is not the case. Although it certainly has to be acknowledged that organizations are responsible for supporting employees’ integrity through the development and implementation of IPs, this does not imply that employees are completely released from their own moral responsibility to act with integrity when IPs lack integrity (Constantinescu & Kaptein, 2015).

Tensions may occur within the framework. For instance, an IP should be stable and steadfast (constancy) while open to change and adaptable (improvement). Likewise, an IP should be customized to the organization while responsive to expectations of external stakeholders. Such tensions within an IP are neither inherent nor inevitable. Constancy should not be understood as rigidity or customization as isolation; the particular situation will tell whether there will be tensions between the internal (organizational) and external (societal) requirements of the IP. When one or more of the framework’s criteria temporarily cannot be met by an organization, due to tensions among the criteria, we believe that integrity management requires finding a way to reconcile these tensions. Even if reconciliation will not eliminate these tensions, the framework is not undermined, because integrity is something to pursue—even, or maybe especially, when there are tensions or difficulties (Kaptein & Wempe, 2002).

Another issue is how the norms developed in this article relate to the effectiveness criteria dominant in the IP literature. The norms developed in this article are based on a deductive approach, but this does not mean that they cannot (partly) overlap with inductively developed effectiveness criteria. For example, the criterion of IP support is also suggested by Brown, Treviño, and Harrison (2005), based on empirical research. Kaptein (2015) proposes the criterion for coherence based on empirical research on the effectiveness of ethics programs. Treviño and Weaver (2003) suggest the IP implementation criterion based on extensive empirical research. Moreover, based on similar studies, Van Montfort, Ogric, and Huberts (2018) composed an extensive set of effectiveness criteria for integrity systems. This set shows some similarities with the currently proposed normative framework, such as the importance of adequate resources and management support for IPs, accounting for specific integrity risks and dilemmas, and employee involvement in the development of the IPs. However, there are also differences from the currently proposed normative framework, such as the absence of criteria for motivation; constancy; integration with adjacent organizational policies; involvement of external stakeholders; and the planning and improvement of IPs. The overlap with effectiveness criteria does not undermine the normative framework. On the contrary, similar effectiveness-based criteria present additional evidence for the validity of the normative criteria. In this respect, more research is needed to determine if and how effectiveness and normative frameworks can support each other. Further research is also needed on how the developed norms and indicators can be operationalized so they can be empirically assessed in organizations.

A final issue to be discussed is the framework’s relevance for the ethics literature. Integrity programs are also often defined as compliance programs or ethics programs (Kaptein, 2015). When used synonymously, the norms for compliance and ethics programs are probably the same as for IPs. However, it should be acknowledged that ethics has a broader scope than integrity (Huberts, 2014), given that organizational ethics also considers issues like ecology, gender, and diversity. Although the developed framework is not designed to be applicable to those aspects of ethics management, future research may determine to what extent the framework may be usable to ethics programs that have a wider scope than integrity programs.

The main implication of the developed framework is that it provides scholars and practitioners who are particularly interested in organizational integrity with a new lens for designing and evaluating IPs. This new lens accentuates, firstly, that without intentional wholeness, the IP lacks authenticity (the IP is then merely a façade to satisfy the opinions of others). Secondly, without organizational wholeness, the IP lacks internal coherence and specificity (the IP is then too generic to fit the organization’s needs). Thirdly, without societal wholeness, the IP lacks contextual embeddedness (the IP is then too isolated to be acceptable to relevant others). Finally, without processual wholeness, the IP lacks adaptive abilities (the IP is then too static to respond to changes).