Abstract

A genuine commitment to ethics and compliance (E&C) programs means that top management adopt them for what they represent and not for other purposes. Only then can they truly build socially responsible behavior and a successful and sustainable business, as stated in the latest international standard for compliance management practice (ISO 37301:2021), which we found to be consistent with a new business narrative as conceptualized in Freeman's work. However, it also requires that top managers place a moral value on these practices, rather than simply using them for instrumental reasons. Building on Kohlberg's six stages of moral development as applied to managers' moral thinking, this manuscript offers a model to explain how top managers' moral valuing of these practices varies along a moral reasoning continuum, resulting in four distinct modes. It also theorizes that each mode of moral valuing yields an archetype of E&C programs. It thus offers a new approach that contributes to the business ethics and management literature by incorporating a morally grounded perspective on the adoption and implementation of E&C practices and how it might shape their features and characteristics. It also aims to improve professional practice and business contributions to Freeman's ideas through genuine ethics‐based E&C programs.