DIALECTICAL INTERACTIONS: DECOUPLING AND INTEGRATING ETHICS IN ETHICS INITIATIVES Spoma Jovanovic and Roy V. Wood Abstract: Evidence abounds that when ethics initiatives are decoupled from the actual work of organizations, ethics policies may become little more than "window dressing" (Weaver, Trevifio, and Cochran 1999; Collen and Gonella 2002). We found, however, an unexpected, positive feature of decoupling in the study of a local government; namely, when organizational members engage In discussions that turn away from the letter of an ethics code they often do so to address higher ethical principles embedded in the spirit of the code. The decoupled understanding of the code in these cases becomes a symbolic, legitimating gesture grounded not in strict provisions but in creative and complex interactions. This counterintuitive explanation of decoupling capitalizes on discourse that evolves from a legalistic interpretation to rich discussions that value the multiplicity of voices within organizational life. What follows is that ethical decision making emerges as creative, dynamic, and responsive to its constituents. Ethics in govemment, like ethics in business, has become an industry to itself. Public tmst in govemment has been waning since the active political agenda of the 1960s' and that has brought with it heightened vigilance toward public servant conduct. At the local level, municipal ethics codes are written to guide behavior of city employees and elected officials, to provide assurance that govemment workers are acting in the best interests of the community, and to encourage greater citizen participation in public service (Davies 1999). The hope is that the code will become an agent on behalf of good govemment. Recent articles in this joumal and others recognize that ethics initiatives can be integrated with or decoupledfi-om the actual work of organizations (Weaver, Treviiio, and Cochran 1999; CoUen and Gonella 2002). Integrated policies create harmony between stated ideals, leadership practices, and practical action. Decoupled policies are marked by a dissonance between the gesture of goodwill and the lack of accompanying good action. High-minded goals are espoused but decoupling means that there is no requisite follow-through (Ashforth and Gibbs 1990). An integrated code contributes to an ethical culture; decouphng leads to mere window dressing. In this study of the integration/decoupling phenomenon surrounding the ethics initiative in the local govemment of a major American city, we found an unexpected © 2007. Business Ethics Quarterly, Volume 17, Issue 2. ISSN 1052-150X. pp. 217-238 BUSINESS ETHICS QUARTERLY feature of decoupling. Tme, decoupling creates an opportunity for people to continue the very behaviors that prompted the code itself. That is because decoupling breaks the connecfion between the ethical ideal and the letter of the code. However, this study shows that this hiatus may generate an equivocality that demands talk about how one should actually function, about what is the right thing to do. The letter of the code makes the ideal seem unrealistic and the ideal makes the letter of the code seem less than ethical. As Weick (1995) argues, equivocality such as this can stimulate sensemaking communication so as to resolve the confusion. And although the equivocality likely to be found in any ethics inifiafive can lead to decoupling, our study considers how such equivocality also can present opportunities for making sense of ethics in ways that ultimately enhance the integration of an ethics initiative. Decoupling and Sensemaking In the pubhc sector, ethics programs are burgeoning at the federal, state, and local levels. By 1990, pubhc administrators recognized that regarding ethics, "govenmient has the obligation to set the example in society" (Bowman 1990: 352). In a follow- up study some years later, researchers found that public officials were still groping for consistent approaches to ethics but that leadership remained a critical force to encourage ethical behavior, and that a properly designed code had the potential to impact daily management practices (Bowman and Williams 1997). Despite the wide and deep respect for ethics programs in govemment circles, often these initiatives do not emerge from proactive management strategies. Peggy Kems, the Ethics Officer for the National Council of State Legislatures, put it succinctly when she said, "In government, ethics law follows ethics scandal" (personal communication, June 23, 2005). Admittedly, governments employ a range of professionals—lawyers, social workers, engineers, law enforcement officers, contractors, and many others—most of whom bring with them their own professional ethics as well as the scmtiny of various regulatory agencies. But top "management," pohticians, and the officials they appoint, live off of public opinion. Post-Watergate joumalism and the increase in pubhc attention following allegations, investigations, and scandals at every level of govemment since then, prompted the rise of formal ethics initiatives and codes. The fact that forty-seven states and most major municipalities have ethics codes suggests that most govenmients have been subjected to the investigadve lens (Maletz and Herbel 2000). Integration and Decoupling Like their private sector counterparts, govemment ethics codes come about because of a combination of environmental factors and intemal motivators (Berman. West, and Cava 1994; Lan and Rainy 1992; Baldwin 1990). They mix mle bound strategies with vision, leadership, and values from leaders. Sometimes, ethics training is provided for all employees while at other times, training is focused DECOUPLING AND INTEGRATING ETHICS IN ETHICS INITIATIVES 219 at the upper level employees within the organization. Regardless of the form, an approach that involves a "critical mass of code users" is necessary to shape an organization- wide ethical culture (Ashkanasy, Falkus, and Callan 2000: 250). And, at issue is whether "the mbber meets the road." Does the ethics program actually affect ethical action in govemment? Extemal pressures, such as public scmtiny, can result in decoupled ethics initiatives that are often httle more than window dressing, designed to placate powerful extemal parties, perhaps utilizing prescribed formal ethical communication approaches in ways that have little real impact on everyday organizational practices (Weaver, Trevifio, and Cochran 1999). Also, a single-minded focus on financial affairs or strategic concems can make it attractive to decouple an ethics program from employees' daily duties. In any case, decoupled programs have instmmental value because they project legitimacy in response to extemal pressures for responsible behavior. By way of contrast, integrated ethics initiatives typically flow from the values and commitments of executives, and are thus often tied to organizational processes such as hiring practices, performance appraisals, and auditing procedures (Bmmback 1991; Weaver, Treviiio, and Cochran 1999). When top leaders make ethics a priority, so too do other employees who see that ethics is anything but window dressing and instead a guide for that organization's practices. A sense among employees that the organization is fair and just, and that there is follow-through on ethics transgressions, results in a decrease in unethical behaviors (Weaver and Trevifio 2001). In fact, the efficacy of ethics programs increases when managers feel that the program matters to the organizational culture, responds to stakeholder wishes, and enhances the ethos of the company (Stevens et al. 2005). Sensemaking Karl Weickfirst introduced us to the organizational processes of loosely coupled systems and sensemaking in his seminal book. The Social Psychology of Organizing (1969) where he pointed out that organizations are constantly evolving and working to make sense of their own existence. This was accomplished, according to Weick, through communication. Weick reckoned that organizing is like the music of a jazz band wherein a little stmcture by the organization and a lot of improvising by its members is what gives life to the culture (Weick 1989). People in organizations are forever assigning meanings to their communicative experiences and interpreting events in their organizations. The interpretations should be considered ethical endeavors, considering how fallibilities of human behavior, standards for excellence, and adherence to organizational mles are manifested in ethical praxis. Weick sees ambiguity, uncertainty, and equivocality at the heart of organizational life. He distinguishes between ignorance and confusion. "To remove ignorance, more information is required. To remove confusion, a different kind of informafion is needed, namely, the information that is constmcted in face-to-face interaction that provides multiple cues" (Weick 1995: 99). Ethics codes provide information BUSINESS ETHICS QUARTERLY about what is ideal and what exactly is allowed. However, another way to see the situafion is to recognize that the potential for an ethics code to address both ideals and specific limits leads to contradictory or equivocal messages and resulting confusion. Interestingly enough, this presents potenfially posidve opportunities for decoupling. It can lead to communicative interaction in ways to make an erstwhile decoupled code a focus of public deliberation, informal conversations and, ultimately, legitimate govemment action. The loose connection a decoupled ethics code has to actual govemment practice can make the code an important symbolic, legidmadng gesture. Would-be decouplers in these situadons work to create a freefloadng ideal that makes the case for taking ethics seriously, thereby generating public support for those within govemment who would take an expansive view of the intended role and requirements of an ethics code.^ Ethics Initiatives and Textual Agency Organizations rely on their ethics code's "textual agency" whereby the document itself acts on behalf of its authors and the organization to affect behaviors that would not exist if there had been no document (Cooren 2004). Borrowing the idea of the "complete organizadon" (Smith 2001), Cooren suggested that documents qua documents are needed to move certain elements of organizadons forward. Of course, bureaucracies are well known as places where managers revere the written word putting everything, especially policy, in wridng. The complete organization thus becomes an organization in which documents state criteria for success (assertives), define objectives (directives), commit employers and managers (commissives), and sanction or reward performance (expressives). (Cooren 2004: 188) Because written documents such as ethics codes carry forceful ardculadons of organizadonal mles, they bear a strong reladonship to the culture of the organizadon itself. As early as the 1970s, Spradley (1979), Goodenough (1970), Geertz (1973), and Bilmes (1976) posited that organizational cultures exist in the context of articulated, even written, normadve mles. Thus, our study uses ethnographic techniques to probe the relationship between textual ambiguities and the resulting talk about ethics. Our goal is to consider how ambiguity, uncertainty, and equivocahty regarding an ethics initiative and its code are played out in a dialecdc of integradon and decoupling. Method Our study of a major American city and its ethics initiative focused on the communicadve action of employees, managers, and board members, benchmarked to the first meedng of a reconsdtuted Board of Ethics in 2001 and extending to 2005. Our overarching research quesdon was "How do people in city govemment talk about ethics?" Our methodological aim was to be as exhausdve as possible in coming to understand how talk about ethics proceeds in the context of a formal ethics DECOUPLING AND INTEGRATING ETHICS IN ETHICS INITIATIVES 221 inidative. The state's Open Meedngs and Records Act gave us access to all public meedngs, pubhc records, and the Board of Ethics files. Our "host" and primary object of study was the city's Board of Ethics. The board restricted us only from their legally confidendal deliberations but they proacdvely included us in all of their meedngs and hearings. Ethics in govemment is not just a standard to be applied to decisions but ethics is also consdtuted in communicadve acdon itself. Among forms of organizadonal talk about ethics, a kind of momentary, actual, dialogic talk is an especially interesdng place to watch the formation of answers to ethical problems that fit real situations at given moments in time. The Ethnography Ethnographers rely substandaUy on the observadon of actual behavior, supplementing that with interviews, and analysis of artifacts and documents to frame their research (Denzin and Lincoln 1998). The goal is to enter into extended interacdons with people in order to "place specific encounters, events, and understandings into a fuller, more meaningfiil context" (Tedlock 2000:455). Criteria for judging ethnographic research involve the following sdpuladons: 1) researcher as pardcipant, 2) focus on culture or adopdon of a holisdc perspecdve, 3) contextual sensidvity, 4) detailed analyses of the social reladons, and 5) theoredcal connecdons (Stewart 1998). One or both of us observedfifty-one meetings of the Board of Ethics from 2001 to 2005.^ We observed the deliberations of an oversight committee on ethics training which met monthly for six months prior to the rollout of the citywide ethics training program. In 2002, we attended six all-day training sessions developed for 105 top-level city administradon staff and elected officials, five trainings for middle managers, and two train-the-trainer sessions. In 2003, we attended three six-hour training sessions for the newly elected mayor and his new administration. In addidon, one of several research assistants on the project collected additional field notes from fourteen other training programs for "rank andfile" city employees." We attended the City Council's committee meedngs involving ethics board and City Council members, and observed one hearing that the Board conducted regarding charges of conflict of interest by a middle manager. We studied all of the inquiries and opinions that passed before the Board. We led five focus group discussions about the training program. We reviewed the key documents and press coverage on the code, and researched a sampling of other city codes across the country. We drafted reports made available to city officials with our recommendations for future action and cridques of what we heard and saw. Our more informal meetings and casual conversadons ran the gamut from a cup of coffee with an outspoken police patrol officer to lunch with one of the City Council members who sponsored the ethics ordinance. In total, we recorded the comments and impressions of 450 city employees, elected officials and board members. At every stage of our research, pardcipants were made aware of the purpose of our research and the reasons for our presence. We made explicit to participants BUSINESS ETHICS QUARTERLY the ways in which we were gathering data and presendng it to city officials and academic audiences. All efforts were made to conceal individual identities except for remarks made in public settings and available to the general public. Institutional Review Board Data collection methods were approved through the Insdtutional Review Boards at both the University of North Carolina at Greensboro and the University of Denver. The project was annually confirmed exempt under 45 CFR Section 46 101 (b)-(3) which includes research "involving the use of educational tests . . . survey procedures, interview procedures or observadon of public behavior where the participants are elected or appointed public officials or candidates for public office." For interviews, an IRB approved consent form was used. Letters and memoranda were rendered anonymous. Analysis of Data We logged approximately 600 hours observing and participadng in discussions with city officials, preparing research reports to benefit the city, collating archives, and providing one-on-one consultadon to ethics planning efforts. Most of the interviews and focus group sessions were audio taped and then transcribed. When tape recording was not possible, we wrote extensive field notes including quotations from city employees, which were then later typed up for distribution to our research team. Last, we have an archive of documents including all of the cases and opinions of the Board of Ethics since 2001, the city's ethics handbook, evaluadon summaries from training, items of pubhc record such asfinancial disclosures, lobbyist registration and activity reports, minutes of Board meetings and City Council meetings, and a variety of letters, memoranda, and reports that employees and officials handed to us. In ethnographic research, the key concem is representation. Do the findings in articles such as these reffect the lives and experiences of the people and processes studied (Coffey 1999)? An on-going process for us was to "check" the claims we made with one another and with the employees and officials in the city in a cyclical reading and rereading of the data in order to develop a description reflective of overt behaviors, collecdve memory, and subjecdve experiences of organizadonal reality (Zilber 2002). Throughout, we asked for other interpretadons and disconfirming possibilides. Ours was a hermeneudc process of leaming and then leaming more at a deeper level through extended contacts. From that, a picture emerges that accounts for the multiple voices and views at work. This process, rather than reliability that seeks stability or consistency, is a preferred mode of analysis in ethnographic research. To achieve measures of good fieldwork, the research team crosschecked assumpdons, observations and conclusions as we interpreted the data independently, and then collectively. We tumed to a key participant in the ethics initiative, one of the most respected pubhc figures in that city to: 1) confirm that our observadons DECOUPLING AND INTEGRATING ETHICS IN ETHICS INITIATIVES 223 reflected accurately the culture we noted and the experiences people shared, 2) to inform him of what had been offered for pubhcadon, and 3) to develop new ideas for interpretadon (Glesne 1999; Patton 2002). Eindings One City's Ethics Initiative The city we studied is one of an ehte few cities across the country that has developed its own code, rather than adopdng some version of a state code or operadng without a code altogether. Yet, it bears remembering the code arose in response to public uproar over a previous mayor's close reladve receiving city contracts, family members being employed (and by implication given preferential treatment) by their supervisors in two different city agencies, and City Council members receiving valuable gifts that might influence their decision making on pending projects. In January 2001, a new Ethics Code passed by a vote of 7-3.^ The executive director of a govemment watchdog group, a forceful proponent of the highest ideals for ethics, declared that the citizens realized a major success in securing one of the country's strictest ethics codes on record. Like many codes, this city's Ethics Code articulates high ethical ideals in its pages, but these ideals are then hmited as pertaining to only certain acdons in certain situations. City employees say that the Umitadons written into the code were polidcal compromises to assure that the ordinance would pass. So, the literal interpretation of the code could in fact be anything but far reaching (i.e., the literal interpretation enables decouphng of the ethics inidadve). This possibility is, however, countered by references, most often in opinions, by the Board of Ethics back to the "spirit of the code" (i.e., the legidmadng force of the code is used to uphold standards more stringent than the letter of the code). The aspiradon to meet the spirit of the code is also reinforced when employees recognize that ethics is distinct from the ethics code, the former being an ideal, the latter being a reasonable standard below which no one's acdons should fall. In light of this, our analysis centers on three pools of data: 1) accounts of actions in which people hold to or extend the spirit of the code as it apphes to questionable ethical activity, 2) accounts of actions that overwrite the ethical ideal implied in the code, and 3) back and forth exchanges about the applicability of the code to actions of certain city officials. The tension over what the Ethics Code is—a document to cover specific possible transgressions following the letter of the code, or a more grand credo for ethical govemment inclusive of the spirit of the code—^results in ongoing back and forth conversation over whether the code is too strict or not strict enough. That dynamic is revealed in critical episodes, some of which follow, resulting in extended debates over how to apply the code and how it might be revised to make it better. Finding #1—Exceptions to the code uncouple stated ideals, leaving employees and the public wondering if the code is in fact just "window dressing." BUSINESS ETHICS QUARTERLY The ordinance establishing the Ethics Code leads off with a statement of legisladve intent that establishes the high ground for the ethics initiative: It is the intent of the city that its officers, officials, and employees adhere to high levels of ethical conduct so that the public will have confidence that persons in positions of public responsibility are acting for the benefit of the public. Officers, officials, and employees should comply with both the letter and spirit of this ethics code and strive to avoid situations, which create impropriety or the appearance of impropriety. In the new code's first three years, 13,000 copies of an ethics handbook were printed and distributed to city officials and employees. To make sure that employees recognized the renewed importance of ethics for the city, the first page included a letter cosigned by the Mayor and City Council President calHng for the "highest ethical standards in our work for the citizens of the [city]." The theme of public confidence condnued with a quotadon by Henry Clay: "Govemment is a tmst and the officers of the govemment are tmstees; and both the tmst and the tmstees are created for the benefit of the people." The ethics handbook addresses the challenge of ethics and public tmst in a straightforward articulation of conflict of interest, gifts, and employment. "The people of [our city] expect you to act for their benefit, and not favor a few individuals or yourself." Conflict of interest becomes possible when the public servant has the capacity to take "direct official action" in relation to a person or endty that is doing, or hopes to do, business with the city. The ethics handbook thus simply and clearly states, "If a conflict of interest exists, you must not take direct official acdon in the matter." It is one thing to ardculate the ideal that all elected officials and employees will eschew conflict of interest and gifts; it is quite another to be so ideal in the context of contemporary organizadonal culture. Gifts to public servants are especially problemadc in a culture where gifting is a prominent feature of the business landscape. When the worlds of business and govemment mb shoulders, the issue is highlighted. During an interview, a senior fire department executive mused upon the difficulties that emerged after September 11. The department became a lucrative marketing target for businesses offering disaster related equipment for sale. Fire fighters were offered trips to luxurious locadons, free samples of clothing and more. The fire fighter told us, "We had no experience dealing with the kind of temptations they offered." Gifts can indeed create a conflict of interest and they have a potential for creadng the appearance of impropriety, undermining public tmst. Thus, the code provides clear direction on this topic: You, or your immediate family members, cannot accept a gift if: 1) You are in a position to take direct official action toward the giver, AND 2) The giver has (or is about to have) a business, contract or regulatory relationship with the City. .. . This prohibition also applies to gifts from a lobbyist or representative of a client if: 1) You can take direct official action toward the client, AND 2) The client has (or is about to have) a business, contract, or regulatory relationship with the City. DECOUPLING AND INTEGRATING ETHICS IN ETHICS INITIATIVES 225 Gifts are defined as gifts or services, things of value, honoraria, loans, tickets, travel expenses, lodging, restricted discounts, and parking passes. Gifts are forbidden except under certain conditions. In particular, the Ethics Code, in its very next paragraph, abmptly establishes excepdons to the clear direction provided in the passage above, overwriting the ideal by sdpulating that the official or employee may accept certain gifts even if the employee or official is in "a position to take direct official acdon with regard to the giver or if the giver is a lobbyist." There are twelve categories of excepdons to the gift mle. Some of those excepdons are benign—gifts from family members, certain awards recognizing excellence in pubhc service, ceremonial gifts required by protocol, and passes to city facilides. Other excepdons to the gift mle may mn counter to high ethical principles. Gifts from other city employees on appropriate occasions and campaign contribudons are allowed as are four meals, tickets, free or reduced admissions, and event parking passes from the same donor in any given year. Section 2-60(b) thus leaves city officials today in a position to solicit and/or accept campaign contributions and receive tickets, meals, and parking from entities over whom they take direct official acdon. Yet, dckets, meals and parking were at the heart of many months of debate prior to establishing the new code. Part of the dissadsfacdon with the old ethics code centered on City Council members receiving coveted tickets to professional football games, free parking passes, and entertainment paid for by lobbying firms. There is no doubt that paragraph 2-60 (b) was a compromise without which the new code would probably not have passed. During the debate about revisions one councilperson avowed that the work of lobbyists was essential to govemment operations and that unless they were excluded or exempted from the provisions of the ordinance, his support would not be forthcoming. So, in the end the majority of City Council members voted that it was essential to be able to continue to accept these kinds of gifts from constituents, those seeking or doing business with the city, and lobbyists. As an apparent safeguard, it was stipulated that the attendance at the meal or event must be reasonably related to the person's official duties.* Proponents of the exceptions typically cited the need to accept invitations to dinners hosted by constituents as part of their official dudes. It is ironic that the code, in deference to this position now requires that the official be in role to accept gifts and as a result actually contradicts the attempt to minimize conflicts of interest. The exceptions to the Ethics Code decouple the ethical premise (e.g., accept no gifts) from actual action (e.g., accepdng campaign contributions and certain meals, tickets, and parking). The design of the code was not accidental; it was a dehberate attempt by some to cast only the appearance of ethics in response to a series of scandals. Some employees and members of the pubhc believed that the exceptions written into the code were the evidence that proved the code was little more than window dressing. Beyond that, the exceptions created a public inconsistency that was often noted by employees when they discussed the code during training. "How can they say they BUSINESS ETHICS QUARTERLY are committed to a strict code and then let themselves take free meals?" Trevifio, Weaver, Gibson, and Toffler (1999) found that consistency between pohcies and acdons matters a great deal. Weaver and Trevifio (2001) found that faimess makes a difference. One can say that when communication around ethics generates a sense of inconsistency and lack of faimess, a subtext is created that uncouples ethics from acdon. Carson (2004) takes us to the heart of the anomahes around excepdons to the code and conflict of interest by identifying two types of conflict. Type one involves a conflict within the many roles that one person plays. If a manager in a position to take direct official action is allowed to accept a personal gift from a prospective contractor, will the managerial self be in conflict with the private self? Will the role of parent interfere with an employee's decision to hire a daughter? Type two is a conflict in relation to different clients or pedtioners. If the manager accepts tickets from prospective vendor A, will A receive preferential treatment over prospective vendors B, C, D, and E? Both of these types of conflict cause confusion and agitadon. It might be tme that campaign contribudons, tickets, meals, and parking are not important enough to the private self to create a meaningful type one confhct of interest. But accepdng such gifts may well create preferential treatment in regard to non-gift giving competitors for contracts, a type two conflict often called "pay to play." Finding #2: The Ethics Board can use the equivocal, free-floating "spirit of the code" to develop and apply new, stricter standards of ethics. Our research, however, reveals a more common impulse toward a very different direction. We routinely observed situations where the force of an ethical ideal emerged to overwrite the very exceptions allowed by the code. Fmstrated managers engaged in spontaneous dialogues about what to do, crafting ethical solutions tailored to the precise circumstances of the moment. Whole departments developed their own codes or tumed to professional codes to enforce higher standards. Throughout, the Board of Ethics has become a critical arbiter that nuances ethics questions. For instance, in more than half of the opinions it offered over a four-year period, the Board of Ethics first approved an acdon under the letter of the code then recommended that the petidoner think otherwise in the context of the spirit of the code or to address the danger of an appearance of impropriety. This move by the Board replicates a process documented by Dobbin and Sutton (1998) wherein organizations often create new, higher-order actions not because the law requires it, but rather because the law does not dictate what right actions to take. From 2001 to mid-way through 2005, the Board of Ethics reviewed 131 cases.' In seventy-four of the opinions rendered (56 percent), the Board mled that the letter of the code allowed the action under quesdon but that there were other considerations to discuss such as: 1) the action was inadvisable and should be reconsidered; or, 2) the action would be advisable only under certain circumstances. The very first case the Board reviewed in 2001 is an example. DECOUPLING AND INTEGRATING ETHICS IN ETHICS INITIATIVES 227 A police patrol officer had a plan to manage parking lots that were located near two popular music venues in his district. He received the required approval from his sergeant, heutenant, and captain. The District Commander passed the request unsigned to the Deputy Chief and it found its way to the Chief of Police who asked the captain in charge of police liability to seek an opinion of the Board of Ethics. The Board heard the case and said while the proposed action technically met the letter of the code, there was great risk of raising the appearance of a confhct of interest between the officer's roles as a policeman and as a parking lot manager. After meedng with the officer, the Board strongly urged that the police department reverse its inclinadon to allow him to proceed in hght of those serious ethical concems. They wrote, [T]he Code states that "Officers, officials, and employees should comply with both the letter and the spirit of this ethics code and strive to avoid situations which create impropriety or the appearance of impropriety." While, as stated above, the Board cannot conclude that managing the parking lots per se constitutes a violation of the Code, the operation for the business could seem to run counter to the above admonition. For this reason, the Board would strongly urge the Police Department to consider whether it would be appropriate to deny the request on the grounds that it creates the "appearance of an impropriety" under the Code. Thus, the Board responded to contradicdons between the spirit of the code and its "technicalities" by suggesting that a technically permissible plan be rethought on the basis of a more ideal ground of ethics. In effect, the relatively free-floating nature of the ideal allowed the Ethics Board the room to interpret it in ways that would narrow the space for potentially unethical behavior. Almost immediately following this case, the Board responded to another in which an employee was asking whether it would be ethical for him to solicit businesses to donate door prizes for an annual charity event. The code allows city employees to solicit donadons to the city for charitable purposes so long as the employee does not keep or use the donated funds or items. So the Board opined that the employee could solicit the door prizes, however it went on to write: In addition, the Board wishes to strongly recommend that no City employee should solicit any types of donations from a person or business if the City employee has any type of regulatory or enforcement or other type of relationship with the person or business. For example, a restaurant owner should not be solicited by a restaurant inspector or by a police officer who patrols that area. The reasoning for this recommendation is that the restaurant owner .. . may receive favorable treatment from the restaurant inspector or the police officer if the owner makes a donation or may receive unfavorable treatment if the owner does not make a donation. As time passed, the frequency of nuanced opinions increased considerably. Between January 1, 2005, and March 2006, the Board mled on thirty-one significant inquiries. In twenty-eight of the cases (90.3 percent, compared to 56 percent for the previous four years) the Board mled that the acdon was ethical under the letter BUSINESS ETHICS QUARTERLY of the code but not advisable under its spirit without modification. Four times, the Board went in the other direcdon saying that the letter of the code suggested that the action was not allowed but that it was probably permissible under the spirit of the code. Even though the volunteer membership of the Board has changed completely due to limited terms, the culture has remained one of talking in the equivocal ground between the spirit of the code and what is technically possible. Remembering that Weick wrote that confusion is the key instigator of sensemaking communication, it would seem that decouphng created an opportunity to talk where one might not have existed in a dghdy integrated code. With high ethical ideals on one pole and a patently weak approach to exceptions and definitions on the other, the situation is ripe for talking about what to do. The Board was able to step into that equivocal space with dialogic forms of talk and improvisadon (Weick 1995). Their mhngs provided detailed explanadon of their thought processes, resulting in suggestions and issues to consider rather than pat yes or no responses. Finding #3—Highly Placed Officials Legitimate Integration of the Board's "Spirit of the Code" by Proactively Consulting with the Board of Ethics. Of course, the Board is aided in this endeavor when city officials proactively consult the Board. This acdon brings added attention to the ethical ideal and the need for ethics in the organizational culture. For instance, in the 2003 mayoral election, the successful candidate came before the Board. He talked to the Board members and suggested that he would be seeking advice in the future on ethical issues that might arise: He said that he intends to "empower ethics in city govemment," that he wants to "keep the cleanest appearance" for himself and the entire govemment and that "perceptions are as important as reality." (minutes. Board of Ethics, June 2003) The Board offered advice to the mayor-elect, a successful entrepreneur, to sequester his business interests from possible conflicts to avoid the appearance of impropriety. A few months later the mayor retumed to ask if it was advisable under the code for him to accept an airline ticket and expenses to travel with the state's govemor to Silicon Valley to recmit business. The Board rendered a strict interpretation of the code advising the mayor that he could not accept the airline ticket since the city leased gates at its airport to airline companies, but he could accept the expenses under the gift exempdons. The presence of the mayor at the Board meedng and his words conveyed a strong commitment to an ethical culture in the city, pardcularly in light of the previous mayor's failure to consult with the Board on hke issues. On October 31,2003, the new mayor attended ethics training with about twenty members of his senior staff. All in all he saw to it that sixty staff members received training. He disdnguished himself in the memories of the Ethics Board staff because he attended the endre six hour session as a "regular student." He paid attention, participated in the exercises, and generally conveyed the impression that the train DECOUPLING AND INTEGRATING ETHICS IN ETHICS INITIATIVES 229 ing was important to him. It was clear to all, and the word probably spread about it, that he takes ethics seriously. There is considerable support for the nodon that acdons such as these by the new mayor contributed to an integrated ethics program. Setdng the mayor's positive words aside, his physical presence, attendveness, and wiUingness to take the role of student of ethics, were all communicative actions that helped constitute and integrate ethics into the organizadonal culture. The previous mayor had attended his training session for only thirty-five minutes, sat off to the side, and appeared to be preoccupied. The two contrasdng mayor stories were discussed in more than one public meedng, including one several years later. Finding #4—Interpretation of the Code Surfaces an On-Going Dialectic Between Decoupling and Integration, the Spirit of the Code and the Letter of the Code. In 2002, the city experienced a pubhc moment of ethical deliberadon surrounding the organizing of a major sporting event. The story that unfolded remains one that is often retold to illustrate the values and conflicts in this city. The city had previously hosted city-wide races in the 1990s. For the summer of 2002, a proposal was put forth by prominent business people to revive the race. Approval from the City Council was needed to allow the use of a major access road to lower downtown, as part of the course. The Council also needed to pass legisladon allowing a suspension of certain ordinances (e.g., traffic mles). Further, rather massive support from the city departments was required to execute the logisdcs of the event. Approval and support was forthcoming and the event was a success. Soon after the race was over, a cidzen filed a complaint with the Board of Ethics that twelve members of the City Council had received complimentary credendals to attend the three-day festivides. Though the cidzen's complaint was directed to twelve City Council people, the Board of Ethics leamed in its invesdgadon that more than fifty city officers, officials, and employees in addidon to the City Council members were offered credendals and that everyone had received invitadons to the race gala as well. The City Council had taken direct official acdon on the race and would neces sarily do so for each year that the race hoped to operate. Council members were invited to attend the three-day event and gala. The lobbyist who had been paid by the business people to work on the racing agreement with the city, the site plan, public safety, and street and transportadon issues also managed the invitadons hst (Office of the City Clerk, public record). Of noted interest is that several of the Council people, including the then president, reported substandal campaign con tribudons from the firm for which the lobbyist worked (Office of the City Clerk, public record). The Board of Ethics issued a detailed mhng. First, the Board reasoned that the six City Council members who used the credendals to attend the event and/or gala BUSINESS ETHICS QUARTERLY did so for official or ceremonial dudes and therefore did not violate the code. The mling was quahfied, however: "The Board of Ethics recommends that the Mayor and Council determine how many officials are needed at an event and develop a method to police acceptance of these types of invitadons so that violadons of the Code of Ethics do not occur." The Board declared that ascertaining what fell within the scope of "official and ceremonial dudes" would be determined in the future on a case by case basis, suggesdng that the current finding could not be generalized. The Board further noted that the four Council people who had not picked up dcket packages had not violated the code because they never accepted any gifts in the form of credendals. Finally, the Board mled that the two Council members who did not use their credendals but gave their dckets to others were in violadon of the code. In short, the credendals acquired value as gifts and lost protecdon as official business when they were passed on to others. In the end, the Board excused the transgressions as "an oversight" with a waming that the Board would not mle similarly in the future. The communicadon between the offices of the City Council and the Board of Ethics about the Board's invesdgadon of the complaint illusd-ates just how seriously elected officials viewed the potendal response of the all-volunteer Board of Ethics. On September 18 the Board received the cidzen's complaint. On September 19, as the law requires, the Board nodfied the City Council that a complaint had been filed. On September 20, a key staffer for the City Council sent a detailed rejoinder to the Chair of the Ethics Board. In it, he summarized and addressed the facts of the case. He argued that the complaint be considered harassment of the City Council because the person had complained at least five other dmes to city agencies. He concluded by declaring that the complaint should be dismissed. The staffer wrote again on September 26. He detailed once more the circumstances of each Councilperson and suggestedfinally that one member asked him to write that "this is getdng silly and invasive. I am sure the Ethics Board should have more to do with their dme than this. Do I have to give them my schedule for the week and have them tell me what I can and can not do?" The staffer's letter reached television news and newspapers the same day. In October, there were three more exchanges between the City Council and the Board of Ethics. On October 8, a very influendal member of the City Council wrote to the Chair of the Board of Ethics about the "Board's disappoindng performance in handling the ethics complaint filed . . . against twelve members of Council for allegedly accepdng race credendals." That person articulated ten specific concems. The concem most cend-al to this study relates to the scope of the invesdgadon: "The Board appears to be acdng on its own inidadve to expand the scope of its analysis far beyond the original inquiry, which it has no authority to do." At the end of the three-page letter, the Board was reminded that some of the current Council members were among the original supporters of the code and thus, "The Council's intent should not be ignored—as it is being ignored in .. . expanding the invesdgadon beyond the complaint. If the Code of Ethics lacks clarity, please let me know and DECOUPLING AND INTEGRATING ETHICS IN ETHICS INITIATIVES 231 I will be happy to work with my Council to amend it." On October 11, the Ethics Board Chair rephed, "I hope this letter answers your concems and I wish to give you my personal assurances that the Board has every intendon of following the provisions of the Code of Ethics and rendering fair and impardal screening and other decisions in connecdon with inquiries." On October 27, the Board dismissed the case on the matter of dckets that were passed on to others, but with the sdpuladon that it "does not intend to do so regularly in the future." The last memorandum came back from the infiuendal member of the City Council to the Board Chair thanking the Board for dismissing a complaint that was of "enormous anxiety" and then reiteradng six failures on the part of the Board. We wonder what chilling effect or other impact the words from the City Council had on the Board of Ethics' deliberadons. For instance, though two City Council members had clearly violated the code, the Board excused the action as an apparent oversight. The Ethics Code was designed to counter a growing culture of influence- peddling through gift giving and to dispel the percepdon of the city being a "pay to play" govemment, yet the City Council throughout the deliberadons leading up to and following the enacdng of the code fought vigorously to limit the scope of the Board's role in monitoring such acdon. This case is hardly an example of significant official cormpdon in city govemment. No one was bribed and we will not claim that any votes were bought for the price of campaign contribudons, dckets, or an invitadon to a party. Those would have been criniinal offenses; the point here is ethics. This case does show that the City Council wrote high ethical principle into law and at the same time drafted a number of excepdons to allow themselves wiggle room. Campaign contribudons and four gift excepdons per year from restricted sources and lobbyists if reasonably related to official business are just two examples. Under this logic, instead of paying for meals, dckets, or parking out of the city's budget or one's own pocket, it becomes a job requirement (or perquisite) to accept hospitality from lobbyists and people seeking city business. Though the race occurred in 2002, we condnued to hear the story told in public setdngs in 2004 and 2005. Ethics Board members view their decision as a good one but also as an instance of how easy it is to raise the ire of people who control appointments to the Board, its budget, and the future of the code itself. Elected officials appear to see the case as an example of the Board's inclinadon to extend its power and as a sign that the Board bears watching. As one City Council member said, "This was a pain in the butt and it was just a waste of everyone's dme." The Board of Ethics' invesdgadon, he said, generated disgmnded people in the City Council. The creative tensions that arise in crafdng an ethical culture are exemplified in cases like this and also in the proposed revisions to the code. Each year, the Board of Ethics has the opportunity to present to the City Council its recommendadons for changes to make the code stronger, clearer, or more expansive in scope. The second dme the Board members attempted such revisions, they leamed quickly that BUSINESS ETHICS QUARTERLY changes would need to be small and mild or else the City Council would allow no change at all. An episode in 2003 illusd-ates this tension. On June 24, 2003, the Board of Ethics began formal discussions of a proposal to the City Council for revisions to "strengthen" the Code of Ethics. At the July meedng, representatives from two cidzen groups and this research project were invited to share suggesdons with the Board. By August 13,2003, a draft of the revisions was completed. One participant in the revision process said, "This is ideal!" At its meedng on August 28, 2003, two weeks later, the Board received a number of cridcal comments about the draft from a City Attomey. The Board resolved to revise the August 13 draft for a formal presentadon to the mayor and City Council in September. It was actually a year later that the final version of the revisions was presented and passed by the City Council. The Board voted to offer at least twenty- one revisions in 2003 but only four remained in September of 2004. The valences during the twelve months of discussion are clear. The dynamics of the discussions were confhct-ridden and threatening. On the one side, there were forces for change from within the Board of Ethics and from informed members of the community. On the other side, some elected officials and some representatives of the City Attomey's office were not hospitable to substandal changes. In the fall of 2003, two key people from the Board of Ethics met with a City Council member who they described as "furious" about the Board's plan for revisions. Hearing that and following discussions in various public meedngs, we as ethnographers would say that the effect was dramadc and chilling. The discussions with people from the attomey's office were also difficult and at dmes a level of animosity was apparent even at Ethics Board meedngs. Reference was made to a confidendal memo in which whisdeblowers had been described as disgmnded employees and to the idea that contracts could be voided because of trivial infracdons of the Ethics Code. At the Ethics Board's May 2004 public meedng, the staff director distributed a summary of twelve "recommendadons that had been dropped by the Board of Ethics after consultadon with City Council members and the City Attomey's office." By September of that year, the proposed revisions to the code were reduced to merely the expansion of three definidons (regarding conflict of interests, private gain, and the extent of a city employee's "immediate family") and a disclosure mle regarding outside business acdvity. Contrasted to what fell away over the previous year—changes in the gift provisions, definidons of the content of conflict of interest, the grandng of mle-making authority to the Board of Ethics, reguladons of solicitadon of gifts to the city, sohcitadon of jobs from potendal future employers, giving authority to the Board to void contracts because of ethics code violadons, and whistleblower protecdon—the four changes that passed were hardly substandve. Still, the Board introduced key items to the discussion and established its right to condnue to recommend changes to the Ethics Code. In other words, they insdtudonalized their voice and condnued a dialecdc about the future of the Code of Ethics. DECOUPLING AND INTEGRATING ETHICS IN ETHICS INITIATIVES 233 Conclusion: The Dialectic Revisited The subtext in this city's ethics inidative has been a dialecdc* between integration and decoupling. Those who seek to advance the spirit of the code and craft an ethical culture depend upon both decoupling interacdons and integrative moves that forward the ideals of the code into everyday action in the city. Those who seek a hmited code sdck to mles, advance excepdons to best ethical pracdces, and argue for making decisions based on the leader's moral compass, without the benefit of interaction with others. Decouphng then, can lead to mere window dressing but it can also travel a different route, one that advances the ethical impulse. A decoupled understanding of an ethics code can consdtute a symbolic, legidmadng gesture that enables creative and complex interactions for communal and societal benefit (Suchman 1995). Understood this way, legisladon becomes a prompt for discussion rather than a hammer of compliance. The decouphng/integradon dialecdc first surfaced during the debates that led to the code. There was heated interacdon about the sentence, "Officers, officials, and employees should comply with both the letter and the spirit of the code and strive to avoid situadons which create impropriety or the appearance of impropriety." The staff director of the City Council described those words as "very controversial" and "at the center of a lot of the debate" (personal communicadon, August 17, 2001). The other point of argument was around the excepdons to the gift provision. One Councilperson said, "I think it is a giant loophole." Her opponent said that in "our zeal to modify human behavior" the code without excepdons "would punish good employees, sending the unethical ones further under the table." Another opponent said that he did not like the idea of a "powerful Board of Ethics." The other camp replied, "We are the visible face of govemment, and it's our responsibility to lead, not lower the bar." The dialecdc has shown itself in the ongoing work of the inidadve when the Board of Ethics mles that a given acdon is acceptable under the letter of the code, but caudons against the acdon on the basis of the spirit behind the code. It shows itself when a Councilperson asks during a pubhc meedng about the code, "Now, what can I take again?" It shows itself when the mayor says, I think if we use the board frequently and openly to discuss the issues we face, we can work by a higher standard. It will give us a clear understanding of why it [ethics] is important, the benefits, the possible pitfalls, and how to achieve our goals at the highest standard. (October 2003 Ethics Training) The dialecdc condnues and, in fact, it may well be a natural feature of ethics inidatives. Some people seize the opportunity to advance ethics in general; others just want to provide window dressing to deffect what they consider unfair scmdny of their behaviors. The ethics of the city in the hfe of the city may be worked out in the ground between the two. BUSINESS ETHICS QUARTERLY This study uncovered the possibility of an unintended consequence of such a strong dialecdc. The letter of the code does indeed decouple everyday acdon from the strong values inherent in the spirit of the code, and from the need for pubhc propriety. However, because the excepdons are extreme and the voice of the ideal is strong, the result is not inaction but rather thought-provoking confusion. This equivocality demands sensemaking dialogue about whether to instantiate the ethical ideal in light of the details of a particular situadon. The code, then, has only the textual agency to begin the discussion, but it is in the ensuing dialogue that each situation is resolved. Overall, we remain opdmisdc about ethics inidadves in large part because the initiative studied created a viable training program and a reladvely strong Board of Ethics. The Board has offered advice and mles in ways that lean toward the spirit of the code, incorporadng high ideals into everyday acdon. The Board consistently avoids legalese and speaks simply as the conscience of the community. Following employee training sessions, we have further observed frank exchanges between employees that have resulted in exemplary acdons involving self-sacrifice for the good of the community. We talked to many individuals who provided stories of acdons that went beyond the letter of the code to take the high ethical ground without any prompdng from supervisors or ethics officials. Time and dme again, employees told us that the Board of Ethics staff director offered invaluable guidance in confidential, informal consultations. Still, a caveat is in order. Countervailing forces, ones that would dismpt sense- making around the code, are ever present. As we have seen in scandals elsewhere, the desire for personal reward can provide seemingly reasonable justification for setting aside an ideal principle. And for employees in every organization, the sheer volume of decisions and fast action required on the job may make it difficult to engage in thoughtful deliberadon about what is ideal and pracdcal. Finally, those who seek power, or those who hope to maintain it, may find a strict adherence to ethics a nuisance. With these threats to the ethics inidative in mind, we find a code of ethics, with communication as a guiding force, a tool for inspiring dialogue. In this major American city, the Board of Ethics is committed to sustained interacdon with employees in advice seeking, complaint fihng assistance, and through training sessions. The mayor, by way of personal example, has been a proacdve supporter of ethics in word, and as importandy, in acdon. Employees, too, reported to us and in employee surveys that the Code of Ethics sets forth a vision that is being reinforced in official action. This city's experience in crafdng an ethical culture through its code and Board of Ethics provides lessons for influencing successful ethics program implementation. First, it is important to articulate the organizadonal ideals, avoiding the temptadon to assume that the ideal is too difficult to attain. Second, one should perhaps realize that excepdons to the mle may not only be polidcally necessary but they also may lead to real talk about ethics—a posidve consequence. But govemment DECOUPLING AND INTEGRATING ETHICS IN ETHICS INITIATIVES 235 officials must carefully craft opportunides for all employees and stakeholders to engage in dialogue about ethical matters so that propriety will prevail and the spirit of the code will transcend the letter of the code. The on-going dialecdc between decoupling and integradon may then be viewed as a healthy byproduct of quesdoning and debate. Notes 1. According to one poll conducted by the Council for Excellence in Govemment (2004) and another by the Brookings Institution's Center for Public Service (Mackenzie and Labiner 2002), only 36 percent to 40 percent of Americans say they trust govemment all or most of the time. The effect is that govemment officials must act with a citizenry in mind that lacks confidence in the stmcture and actions of our municipal, state, and federal resources. To reverse this trend thirty years in the making (with the notable exception of a spike of support for govemment following September 11, 2001, that was not sustained), govemment bodies are tuming to ethics codes to strengthen their ethical cultures to regain the public's tmst. 2. We are grateful to the editor and anonymous reviewers for providing valuable guidance and assistance in the development of the ideas presented here. In particular, one of the reviewers pointed out the risks and possibilities for would-be decouplers that we believe capttires fully the tensional dynamic of communicating ethics. 3. We wish to acknowledge the Carl M. Williams Institute for Ethics and Values at the University of Denver for a grant awarded through the Center for Civic Ethics, and also faculty research grants from the University of North Carolina at Greensboro. 4. Susan Sci, Kate Zittlow Rogness, Rob Margesson, Linda Olson, and Elaine Gale contributed many hours of observation and data collection to this ethnographic project. 5. Employees, the staff director of the Ethics Board, and the outside ethics trainer refer to the margin of victory as one vote. Though there are thirteen council people, three were absent on the night the vote was taken. The drama of a one-vote margin seems to be offered to underline precarious support for the code and perhaps for ethics in city. It is also cited as a waming to those who would push too hard for a stricter code. 6. To place this city's Ethics Code in context, we looked at the codes of neighboring govemment agencies as well as a sample of other municipal codes around the country. The state's law stipulates that it wants to restrict gifts that could infiuence reasonable people or be constmed as rewards for official action, yet it is qualified by a laundry list of exclusions of the very gifts that are routinely used to influence officials or gamer favor. Defining such items as exclusions (including campaign contributions, meals, travel expenses, and tickets to events) effectively removes them from ethical consideration. Many cities do not consider gifts to be gifts until the monetary value is of a certain amount. Eor example, one major city—-widely recognized for its liberal political posture—exempts gifts valued at up to $50 from ethical consideration. In a large West Coast city, officials are limited to accepting an aggregate amount of $300 from sources in general, $100 from restricted sources (those sources with whom govemment employees are doing business), and $25 from lobbyists. In a Midwest state capital city, a gift is not a gift until it is valued at over $200. The gift exception mles fail to consider the impact of the norm of reciprocity. In a study of seemingly trivial gifts to physicians, researchers found that gifts as small as ball point pens do infiuence future behavior (Katz, Kaplan, and Merz 2003). The result is. BUSINESS ETHICS QUARTERLY from a moral and regulatory perspective, policies that determine the acceptability of a gift according to its size is unsound. The power of gift-giving, both large and small, must be acknowledged if appropriate regulatory policies are to be created and enforced. (Katz, Kaplan, and Merz 2003: 44) Still, such a hard and fast mle as "no gift-giving" is either too difficult to enforce, or undesir able for employees. As a result, the question of undue infiuence from small gifts looms within govemment circles. 7. 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