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How many times have you heard a business leader say something like, “Doing the right thing is in our DNA; it’s just who we are”? Maybe you’ve said it yourself; I know I have.
On the surface, that premise is hard to argue with. It’s a powerful affirmation of identity, positioning values as a social norm—part of the organization’s fabric. For an employee facing a tough decision (or even an easy one), it signals that the “right” choice should feel natural and expected.
Or…maybe not.
A recent Harvard Business Review article summarized a series of experiments on the science of behavior change. The researchers questioned whether framing corporate values as “who we are” might unintentionally create complacency. If integrity is already in our DNA, then is it something we still have to actively work on?
So they tested an alternative: framing values as aspirational goals, something that we can always get better at.
The result? “Managers who had received a more aspirational ‘We know we can do more’ framing were more likely to commit to having a conversation about [the targeted behavior] with their teams,” HBR reports. “Their teams were then more likely to report that their leader had created an environment in which employees felt comfortable raising concerns.”
Values are Something to Strive For
In other words, when values are positioned as something to strive toward rather than something already achieved, leaders are more likely to act, and employees are more likely to feel it. For those of us working in ethics and compliance, the implications are immediate.
At Ethisphere, we’ve long emphasized the importance of regular, manager-led conversations about ethics and compliance. And our culture data—now encompassing more than 4.8 million employee responses—consistently reinforces this point. We see that when managers discuss ethics or compliance topics “frequently” (defined as at least once per month), employees are significantly more likely to:
- Say they would speak up if they observed misconduct
- Feel comfortable raising concerns with their manager
- Trust their company’s system of organizational justice
Compared to employees whose managers discuss these topics “rarely” (about once per year), the difference is meaningful. The HBR research adds an important nuance to ours: it’s not just whether or how often managers talk about ethics; it’s also how they talk about it.
HCA Healthcare: Culture and Commitment
Founded by two physicians and a businessman in 1968, HCA Healthcare, a healthcare provider with hospitals across the United States, has been putting this theory into practice for decades. Following a merger with another health system in the late 1990s, the company strayed from its founding principles. Upon the return of its founder as chairman and CEO, HCA Healthcare began the difficult work of restoring its culture and resetting its values. Like many organizations in similar circumstances, the company’s response included building a robust compliance program and investing deeply in embedding a culture of ethics and integrity. Today, HCA Healthcare is a 15-time World’s Most Ethical Companies® honoree and 2025 recipient of Ethisphere’s Compliance Leader Verification. For more than two decades, ethical behavior has been core to the company’s DNA, shaped by hard lessons and a commitment to operating with integrity.
But the Ethics & Compliance team, led by Wendy Warren, SVP and Chief Ethics & Compliance Officer, recognized an important reality: many of today’s employees weren’t there in the late 1990s and early 2000s. If integrity is grounded only in history, it risks becoming abstract. So HCA Healthcare’s compliance team is working to connect integrity and other core value behaviors to the company of today.
Her team and others started with what already resonated: HCA Healthcare’s mission—“Above all else, we are committed to the care and improvement of human life”—and the company’s widely embraced slogan, “We show up.” But the company’s values themselves? They were less top-of-mind.
Rather than reinventing the wheel, the company is reframing the connection so that the values became the how behind the mission and “we show up”.
By reinforcing behaviors tied directly to the mission and values, HCA is giving employees a practical lens to guide everyday decisions. It prompts a simple question: What does it actually look like to show up with integrity—for our patients, for our colleagues, for our community? That framing is now being woven throughout the organization through internal communications, with more to come.
Ground Yourself in Ethical Principles
At a broader level, this approach also reshapes how the ethics and compliance function shows up. Rather than leading with rules and requirements, the program is anchoring in shared values and visible behaviors. Compliance becomes the natural outcome of a culture grounded in ethical principles and behaviors, not the other way around. As Wendy puts it, “If we’re leaning into the values that are behaviors, that really is, for us, where we believe the magic happens.”
Magic might feel like a strong word in compliance. But when you combine consistent manager conversations with values framed as something we actively practice, not something we assume we already possess, the impact can feel transformative.
Integrity may be part of your DNA—but it still needs exercise.
Author Bio
Emily Miner | Director, Data & Services, Ethisphere
Emily is a Director at Ethisphere in the Data & Services team. Her work includes evaluating client’s ethics and compliance programs, benchmarking against peer practices, providing guidance and implementation support to early-stage programs, and developing compliance and ESG risk assessments.
