This article argues that three key elements must exist if illegal or unethical activity within and on behalf of organizations is to be minimized for developing and sustaining an ethical corporate culture. The three elements include. (1) the existence of a set of core ethical values and fused thought the organization and its policies, processes, and practices; (2) The establishment of a formal ethics program, including a code of ethics, ethics training and ethics hotline and an ethics officer; and (3) The continuous presence of ethical leadership that is an appropriate 'tone at the top' As reflected by the Board of Directors, senior executives and managers. While each of these three elements is distinct, they also overlap, relate to, and reinforce each other. What is the main theme of this Abstract