Code of ethics and the telemarketing industry's code

PETER 5. CARUSONE HERBERT E. BROWN GORDON L. WISE

Code of Ethics and the Telemarketing Industry's Code PETER S CARUSONE. PhD. is a professor of marketing at Wright State University in Dayton, Ohio. where he specializes in consumerism and social issues in marketing He has served on the staff of Federated Department Stores and The C/nc/nnat/Enquirer He has served as a Consumer Advocate on the Chrysler Corporation Arbitration Board and also participated in the J C Penney Consumer Affairs Forum HERBERT E BROWN. PhD, is professor and Chair of Marketing at Wright State University. where he teaches direct response marketing. including a course in telemarketing He is the author of Readlngs and Ca5es / n Due0 Markecmg. the instructor's guide for Bob Stone's Successful Dmcr Marketing Methods, and numerous articles on the direct marketing field He 18 currently doing research on job satisfaction in telemarketing GORDON WISE is a professor of marketing at Wright State University. where he teaches advertisirig and other marketing courses. His extensive publication list includes articles in numerous professionaljournals. including a recent study on heavy and light-user perceptions of selected direct marketing channels This article was presented at the Second Annual Robert 6 Clarke DMEF Educators' Conference, held in San Francisco last October It was one of two presentations which were each awarded a S I .ooOcash prize (the other, by Arch Woodside and Praveen Soni. will appear in the next issue of JDM) The conference is named in honor of the late Robert B Clarke, former Chairman and CEO of Grolier. Inc , who provided an endowment fund for academic prizes in direct marketing education.

PETER S CARUSONE

HERBERT E. BROWN

GORDON L. WISE

ABSTRACT This article examines the role of the code of ethics in the context of other approaches to institutionalized improvement in business ethics, and reports the results of an empirical study among on-thephone telemarketing personnel regarding their support o f various ethical tenets embodied within the industry's professional code. The results indicate that practicing telecommunicators do not indiscriminately support or reject the various tenets of the 12-tenet code. Clarity and honesty in presenting telemarketing offers received the strongest endorsement. Conversely, however, there was significant disagreement with other tenets that called for n o telemarketing deceit. The tenet prohibiting delivery o f recorded messages without first obtaining permission w i t h a live operator received the least support. Implications of the findings suggest that a concerted industry educational effort i s needed o n telemarketing's code of ethics. There i s also the possibility that the code itself may lack the specificity necessary t o make it work up to i t s greatest potential as an institutionalized tool of telemarketing3ndustry self-regulation. 0 1971 J o h n Wiley & Sons, Inc. and Direct Marketing Educational Foundation, Iiic. CCC 0872 0591/91/0107-08$04.00

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Unfavorable publicity, pressure from public interest groups, and the high cost of complying with government rulings (13) have made the business community increasingly aware of, and concerned about, ethics. Public and private sector enterprises have responded in a variety of ways. This article provides a general overview and discussion of the “code of ethics” response, then evaluates the attitudinal consistency of telephone sales personnel with tenets of the telemarketing industry’s code of ethicso n e of that industry’s responses to the ethics problem.

STRATEGIC SOLUTIONS A wide variety of strategies have been offered to

help ameliorate the business ethics problem and make it a priority issue in corporate America. Practical proposals include: codes of ethics, ethical policy statements, leadership, ethical ombudspersons, ethics committees, realistic performance and reward plans, ethical corporate cultures (17 ) ,conferences, training programs, ethical audits (IS), ethics seminars, and the linking of performance appraisals to reward and incentive programs (10). These approaches seem to fit into three major categories, exemplified by: 1) use of ethics consultants; 2) certification of competence programs; and 3 ) codes of ethics. The Ethics Consultant

Professional ethical consultants, or business ethicists, are increasingly visible players in the ethics improvement movement. Cynics sometimes say it’s difficult to determine whether a company hires ethics consultants because it cares about ethics or because it merely wants to look as if it cares (22). But, whatever the case, ethics consultants are here and are likely to stay and contribute to the common goal of raising the organization’s ethical consciousness by helping employees think more clearly about the complex ethical questions they routinely face. Consultants make a very important contribution by serving as watchdogs for corporate misconduct, an assignment they can do well when there is sufficient encouragement and open support by the

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CEO (20). They also help design and implement comprehensive ethics programs to transform the corporate ethics culture. As outsiders, consultants can perform evaluations with much greater reliability and objectivity. They also can weave value themes and ethical principles into management training, corporate policy and strategy statements, and have an important influence on decision making at all levels (12). Certification of Competence

Another solution to the ethics problem is the use of “competence certification.” This approach requires academic preparation in ethics as well as conformance to suitable ethical standards. Many public relations professionals, as one example, believe that ethics competence certification would be preferable and more useful than codes of ethics. When competence certification is fully developed for this profession, its most visible element would be a National Academy of Professional Communication. This academy would work in concert with existing organizations to establish and enforce a national code of ethics, and would administer a national certification program requiring continuing education and training ( 4 ) . This would be the pattern in all industries that adopt this approach. Codes of Ethics

Codes of ethics represent the most frequently used method of institutionalization of ethical concerns (9). They are developed within a company or an industry, and thus constitute a form of self-regulation. The majority of ethics codes rely on internal controls rather than external enforcement by outside agents or agencies. However, authorities tend to agree that codes are ineffective unless there are some disciplinary measures to punish offenders and reward persons who adhere to the code. Codes of ethics can serve both normative and descriptive purposes. NORMATIVE. One expert recommends that the initial step in ethics improvement should be the development of written codes of ethics or standards of conduct, which are then incorporated into the corporate culture and communicated to all employees through education programs ( 4 ) . If such codes are to function effectively, they must insure

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that reasonable individuals will not risk engaging in unethical acts. For this to happen, it is recommended that four steps be taken. These are: draw a clear distinction between acceptable and unacceptable behavior, such as through a published code of ethics; emphasize that the code is not just a set of platitudes; communicate sound advice about the code’s interpretation; and establish disclosure mechanisms to expose those who violate the code (11). DESCRIPTIVE. Other experts take a different, and somewhat cynical, point of view concerning codes of ethics. They suggest that codes do not create standards of good behavior, but rather just record them. Business ethics are developed, they say, and are not made simply by neatly written phrases (16). There is merit in this perspective, because the usefulness of any given code of ethics i s certainly dependent on the extent to which it is able clearly to address some common ground of moral judgment and ethical value. Most experts agree that to ensure a measure of common ground in resolving conflicts of opinion, it is also important to insure that code standards are clear, enforceable, and consistent (6). Furthermore, to function effectively as a legitimizing document, the code must be expository, analytical, and evaluational. Finally, an effective code must also: include clearly defined terms; offer succinct examples; clearly analyze and evaluate problems; indicate the standing of the law on issues; classify and divide troublesome groupings of concepts, terms, practices, or principles; and openly admit if an article or principle may be subject to personal interpretation ( 7 ) . Unfortunately, many codes are “encoded,” i.e., loaded with inferences and symbology unique to a particular occupational or industry group. Often, too, the group is seeking to portray to the publicat-large certain group values, norms, and responsibilities in lieu of, or in addition to, providing to its members a working document that might be useful in dealing with ethical situations. For example, the Code of Professional Standards for the Practice of Public Relations contains implicit and explicit attitudes toward the public and toward the truth. Faced with ethical dilemmas in these areas, public relations professionals should be able to find clear direction in the official code, but they usually cannot ( 5 ) .

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CODES OF ETHICS LIMITATIONS Most of the major limitations, or shortcomings, of codes seem to stem from neglect, misuse, or undue reliance upon them, rather than upon any inherent deficiency in the nature of codes themselves. It is a fact that n o single satisfactory standard of ethical action exists that is agreeable to everyone (8). Obviously, it is naive to believe that all a company needs to build integrity into an organization is a well-communicated code of ethics (23). For example, General Electric, caught in a price-fixing conspiracy in 1961, subsequently promulgated an ethical code that did not prevent the company’s cheating the IJ.S. Air Force of $800 million in 1985 (15 ) . The clearly apparent fact is that a code of ethics must be backed up by many support systems within the organization if it is to work (3). The rapid globalization of markets and the differing cultural values of managers in different countries also dampen the effectiveness of codes of ethics. A comparative study of the attitudes of French, German, and U.S. managers regarding ethical business philosophy and codes of ethics, indeed, turned up some interesting similarities and differences that need to be addressed. The findings suggested that French managers were generally idealistic and more optimistic than others regarding the effects of ethical codes. The Germans appeared to be relatively pessimistic regarding the efficacy of codes. U.S. managers, whom the study termed realistic, disagreed most strongly with the statement, “Let the buyer beware.” All groups generally agreed, however, that good ethics-whatever they are-make for good business (2). Ethical problems derived from crosscultural differences are likely to become increasingly important in view of the anticipated elimination of trade barriers among European Community nations in 1992.

Codes of Ethics in the Telemarketing Industry

Direct marketers have worked to mesh the various codes of ethics in various countries in such a way that they will have the same system everywhere, thereby creating a more hospitable environment for direct marketers (19). As a result, the direct marketing industry, and more specifically, the telemarketing industry, already has what it believes to be a strong, and international, ethics code.

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Experts believe, however, that if it is to work, an industry code of ethics, such as the DMA’s Telemarketing Code of Ethics, must have the support of a significant number of the people for whom it is written. This is especially true for codes that do not provide sanctions for violating guidelines ( 4 ) . Biting, punitive sanctions are not included in the DMA’s code. Thus, if it is working, this is because it is supported by a significant proportion of the people who are currently implementing telemarketing strategies. Testing telecommunicator support for the direct marketing industry’s telemarketing code of ethics was the objective of a summer 1989 research study which focused o n the Direct Marketing Association’s telemarketing ethics code. In that study, 141 onthe-phone personnel from 12 companies were surveyed to learn the extent of their agreement with the ethical standards asserted by the code. The target population for this study consisted of all employees who were directly involved with onthe-phone telemarketing sales work in 12 randomly selected telemarketing organizations in o n e sector of a highly industrialized Midwestern state (see Table 1). The nature of telemarketing operations surveyed ranged from newspaper subscription sales to business-to-business computer software sales. In-

bound, outbound, and combined inbound-outbound operations were represented about equally, as were business-to-business, business-to-consumer, and combined business and consumer operations. All data were collected by a survey questionnaire delivered directly to the subjects by the researchers at their worksites. All respondents were given postage-paid, business reply envelopes in which to return completed questionnaires directly to the researchers. The cover letter which accompanied the questionnaire explained the nature of the study and assured respondents of anonymity and confidentiality of the data provided. O n e hundred eighty questionnaires were distributed to subjects. A total of 141 usable questionnaires were received, for a return rate of 78 percent. The data collection instrument was the Direct Marketing Association’s Telemarketing Code of Ethics modified very slightly to facilitate use on the research questionnaire. A seven-value Likert-type scale was used, which provided respondents with options ranging from “strongly disagree” to “strongly agree” for each of the code’s major tenets for telemarketers. The entire code/questionnaire is shown in Table 2.

TABLE 1 Sample Profile Firm‘s Business Computer-assisteddesign services

Inbound ( I ) Outbound (0)

Approximate Group Size

Sample Contribution

Principle Call Type

i&O

9

6

Lawn care services

0

12

11

B-C**

Newspaper advertising

0

10

21

B-B

B-C

Newspaper subscriptions Savings & loan financial services Computer peripherals Labeling equipment

B-B*

0

4

4

I &O

10

I2

B-C

I

25

23

B-C, B-B

I&O

31

22

B-B

Medical supplies

0

5

5

B-B

Quality control PC software

0

12

9

B-B

I&O

25

13

8

5

Computer supplies Fabricated steel Telemarketing service bureau

0

I&O

2

Jl

180

141

B-C. B-B 8-B

B-C. B-B

* Business.to-business operation ** Business-to-consumeroperation

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TABLE 2 Results of 12 Telemarketing Organization Survey 14 1 Respondents Tenets of the Direct Marketing Association’s Telephone Marketing Guidelines (TI to TI21

Disagreement 1-2

O n the Fence 3-4-5

High Agreement 6-7

1 %’

4%

95%

9

89

21

77

TI.

All telephone offers should be clear, honest and complete, so that the recipient of the call will know the exact nature of what is being offered and the commitment involved in placing order

T2.

Telephone marketers should remove the name of any contact from their tetephone l i s t s when requested to do so

T3.

Telemarketers should promptly disclose seller’s name and the primary purpose of the contact

T4.

Telephone marketers should be restricted to making calls only during hours the recipients of the calls consider reasonable

9

22

69

T5.

Telephone marketers should honor all cancellation requests which originate within three days after a sales agreement has been made over the phone

9

22

69

Tb.

Taping of telemarketing phone conversations should not be permitted without first obtaining the customer or prospect’s consent

17

24

59

12

30

58

2

47

51

T7.

It i s wrong for telemarketers to make offers or solicitations in the guise of research when the real

T8.

No telephone marketer should solicit sales using automatic dialing equipment unless the telephone immediately releases the line when the party disconnects

intent i s to sell a product or service, or to raise funds

T9.

Telephone marketers have a special obligation to deal in especially sensitive ways with minors. the elderly, and other groups with special vulnerabilities

13

37

50

T10. A law requiring all telephone marketers to disclose ALL terms and conditions, charges, etc , BEFORE being allowed to ask the customer for a commitment would be a good idea

23

30

47

TI I . Marketers do not have an undisputed right to call unlisted or unpublished numbers, via random dialing and the like

19

34

47

TI2. Recorded messages should not be delivered to any prospect unless permission has first been obtained by a live ”operator”

15

41

44

Scale 1 = Strongly Disagree, 2 = Disagree. 3 = Slightly Disagree, 4 = Neither Agree or Disagree. 5 = Slightly Agree, 6 = Agree, 7 = Strongly Agree N = 14 I Figures in the three right hand columns represent percentages throughout the table

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RESULTS OF THE SURVEY

The range of variation in the responses clearly indicates that a discriminating attitude exists among telecommunicators toward the various tenets set

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forth in the DMA’s telemarketing code of ethics. There is clearly neither rote acceptance nor rejection of the entire package of guidelines, and there is clearly more agreement than disagreement with industry guidelines.

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All tenets of the DMA’s telephone ethics code were supported by from 44 to 95 percent of all survey respondents. Three tenets received support from 75 to 95 percent of the study’s 14 1 respondents. Interestingly, the guideline receiving the highest level of support was clarity, honesty, and completeness in telephone-delivered offers to sell. The tenet which received the second-highest level of support was “removing names of callers who don’t want to receive telemarketing calls” from their calling lists. Prompt disclosure of seller name and purpose of contact was supported by 77 percent of all respondents. Six tenets received support from 50 to 75 percent of all survey participants. ‘These included: restrictions o n calling times, honoring requests for order cancellation, taping phone conversations only with customer consent, not selling under the guise of doing research, limitations on the use of automatic dialing equipment, and sensitivity to groups with special vulnerabilities. Only four tenets received support from less than a majority of all respondents. The code requirement that live operators be used to obtain permission before presenting recorded messages received only 44 percent support. Forty-one percent of respondents remained “on-the-fence”o n this issue. Fortyseven percent supported the code guideline prohibiting calling unlisted numbers obtained via random dialing or other methods. Forty-seven percent agreed with the notion that all terms and conditions of telephone channel-generated sales should be disclosed before asking the customer for an order. DISCUSSION

Explicitly or implicitly, such issues as honesty, fairness, privacy, annoyance, deception, and the like, are the foundation on which the Direct Marketing Association’s Telemarketing Guidelines rest. In view of this fact, survey results can be examined in the context of these values. They also can b e examined from a legal perspective. Honesty:The very core of ethical behavior, honesty, is raised as an explicit part of Tenets 1 and 3 . These tenets require, respectively, clear, honest, and complete offers and up-front disclosure of cafler name and purpose of the call. Only five percent of all respondents had any reservations about the

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“clear, honest, and complete offer” requirement of Tenet 1. Furthermore, eight of ten respondents agreed that caller name and call purpose disclosure is the right thing to do. However, only 6 out of 10 respondents strongly agreed with Tenet 7, which prohibits deception through solicitation in “the guise of research.” Thus, o n what appears to be a clear-cut “deceive” or “not deceive” issue, four out of 10 respondents effectively agree with the “deceive” position. Fairness: Fairness, in the sense of going by the rules, not being devious, and so forth, is prescribed by several tenets of the telemarketing ethics code. Among these is Tenet 2, where responsiveness of telephone marketers to requests for name removal is specified. Eighty-nine percent of respondents approved this tenet. This is true also for Tenet 8, where limitations are specified o n the use of automatic equipment. However, this is endorsed by only 51 percent of all respondents. Fairness is also specified in Tenet 12, which provides additional limitations o n telemarketer use of automatic equipment. This was endorsed by only 44 percent of all respondents. Clearly this area needs evaluation by the telemarketing industry. Disclosure:The issue of disclosure is an element of Tenet 3 , where the focus is more o n timely or prompt disclosure of selective information. Seventyseven percent believed in prompt disclosure of caller name and call purpose. Disclosure also underlies Tenet 10, where the concept of full disclosure (of all terms, conditions, etc.) is prescribed, and elicited strong agreement by less than a majority of all respondents. This finding calls into question the industry’s commitment to clear, honest, customer-oriented communications. Privacy Issues:Though the telemarketing code of ethics does not mention privacy specifically, it does contain three provisions with heavily-implied privacy content. One of these, Tenet 4 , concerning time periods when consumers are entitled not to be bothered by commercial telephone calls, is supported by a two-thirds majority. O n the other hand, Tenet 6, concerning the seller’s right to tape conversations without permission, and Tenet 11, concerning calling unlisted numbers, garnered only 59 and 47 percent support, respectively. These findings suggest that on-the-phone telemarketing personnel are not as committed to the industry standard of customer privacy as the framers of the code feel

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they should be. These attitudes are n o doubt contributing to the highly contentious nature of the privacy debate swirling around telemarketing. The issue of privacy in direct marketing is one of critical concern in the industry. The fact that many things can be learned about people without their knowledge, and used to commercial advantage, is a situation that implies potential dangers for both direct marketers and their prospects and customers. Hence, how to share information is one of the most pressing issues direct marketers face. Undoubtedly, the industry will have to develop and communicate a much stronger stance on the issue of privacy to its on-the-phone personnel (1). The law: It is particularly surprising, and disconcerting, to see the respondents’ disagreement with items that not only represent an aspect of ethical behavior but also are imbedded in the law. Tenets that obviously fall into this category include Tenet 5 o n cooling-off period, Tenet 9 on treatment of minors, et al.,-as in the “Wayward Fool” doctrine, and Tenet 10 on disclosure of terms. SUMMARY AND CONCLUSIONS

O n the surface, it looks as though there is “substantial agreement” with most of the ethical issues embodied in the telemarketing code. Respondents who are in agreement, for the most part, outnumber those who are not. But this is not good enough. We are not talking about baseball batting averages or presidential election returns. We know, of course, that behavior is a function of attitudes, opinions, and beliefs. What, then, is the effect of the one out of five telemarketers who disagree with the notion of restricted contacts of unlisted numbers? Does that constitute a significant problem? If 4 2 percent of calls emanate from companies whose personnel have no qualms about saying, “This is research,” what is the effect on the consumer? O n the industry? The results of the survey reported here cannot be labeled satisfactory, nor can it be said that the use of a code of ethics in the industry has had enough of the desired impact. Codes can be helpful only if there is general agreement that certain unethical practices are widespread and undesirable. General agreement is lacking here. Any program to institutionalize ethics must take into account the contentious nature of marketing in

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general and selling in particular. After all, whenever we ask for the sale, our goal is for the customer to abandon-or displace-some current mode of behavior with respect to the problem at hand, thereby raising a certain level of psychological discomfort, or dissonance which manifests in the form of objections. To anticipate and take measures to minimize objections, resistance, and possible rejection, sellers will always be subject to the temptation to bias the selling message, ask for a commitment before disclosing all terms and conditions, etc. These kinds of pressures toward unethical behavior must be recognized, confronted, and replaced with a strong statement of ethical policy, incentives, and specific operational guidelines for which employees will be held accountable.

IMPLICATIONS FOR DIRECT MARKETERS

Unless the telemarketing industry sincerely believes in ethics and consistently emphasizes ethics to its telecommunicators, the industry is likely to remain extremely vulnerable to public outrage, media pressure, and the prospect of extensive government regulation. The message is clear: “It is our responsibility to adopt an active zero-tolerance policy toward all marketing transgressions we come across, in our own organizations as well as others” (21). This is especially applicable to telemarketers, as with any sellers who are in a position to so easily violate individuals’ right to privacy. “Compensation plans may need to be readjusted. There are now too many built-in incentives to cut corners, take the short-term view, focus internally rather than on the consumer, and play fast and loose with ethical issues” (21). Penalties for infractions of ethical behavior may serve as disincentives to cut corners, but they must be specific, clearly communicated to all employees, and evenhandedly enforced. For example, sales managers who fully subscribe to the code ought to randomly monitor their telemarketing sales reps for violations, with probation for a first offense and, perhaps, termination for a second offense. In either case, a follow-up apology to the consumer would certainly be in order.

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DIRECTIONS FOR FURTHER RESEARCH

There are two major avenues of further research suggested by the findings of this study. These are: 1) questions of how best to enforce the code of ethics, i.e., what punitive measures should work best; and 2) how can code of ethics tenets best be integrated into an overall telemarketing ethics improvement strategy. Enforcement is a key issue. The effect of various measures by which enforcement of an industry ethics code might be achieved must be explored. Research is needed in areas such as employee motivations, points of resistance, tradeoffs in compensation packages, negative versus positive incentives, and so forth. Testing to identify the “ethics resistant” mentality represents a rich area for in-depth research. Codes of ethics can be, and typically are, used in isolation, or they can be integrated more closely with the use of the ethics consultant, certification of competence, and other ethics programs. Comparative studies of these scenarios can provide the industry with approaches for measuring costs and assessing possible payoffs of alternative approaches to the industry’s “ethics management” problem. REFERENCES 1 . - (1988),“A Question of Privacy,” Target Marketing, November, 12-13. 2. Becker, Helmut and Fritzsche, David J . (1787), “Business Ethics: A Cross-Cultural Comparison of Managers’ Attitudes,” Journal of Business Ethics, May, 289-295. 3. Brown, Ahby (1987), “Is Ethics G o o d Business?” Personnel Administrator, February, 67-74. 4. Brown, David H. (1986), “A Funny Thing Happened o n the Way to the Forum o n Ethics,” Public Relations Quarterly, Spring, 20-23. 5. Buchholz, William James (19891, “Deciphering Professional Codes of Ethics,” IEEE Transactions on Professional Communication, June, 62-68. 6. Castleberry, Stephen B. and French, Warren A. (1987), “Reviewing the MRA’s Code of Ethics,” Journal of Data Collection, Fall, 42-48.

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7. Ibid. 8. Caywood, Clarke L. and Laczniak, Gene R (1986), ”Ethics

a n d Personal Selling: Death of a Salesman as a n Ethical Primer,” Journal of Personal Selling & Sales Management, August, 8188. 9. Cressy, Donald R . a n d Moore, Charles A. (1983), “Managerial Values and Corporate Codes of Ethics,” California Management Review, 25(4) (Summer), 53-57. 10. Gandossy, Robert P. (1988), “The Tough Job of Shutting Down Corporate Fraud,” Management Review, September, 3943. 1I . Gellerman, Saul W. (1989), “Managing Ethics from the Top Down,” SIoan Management Review, Winter, 73-79. 12. Guerrette, Richard H. (1988), “Corporate Ethical Consulting: Developing Management Strategies for Corporate Ethics,” Journal of Business Ethics, May, 373-80. 13. Halcomb, Ruth (1986), “Incentives & Ethics,” Incentive Marketing, October, 36-39, 67. 14. IIennessy, Edward L., Jr. (19861, “Business Ethics: Is I t a Priority for Corporate America?” FE: TheMugazineforFinancial Executives, October, 14-19. 15. Hill, Gladwin (1987), “The Shifting Sands of Public Consent,” New Management, Spring, 47-50. 16. Klein, J. (1932), “Factors in Business Behavior,” in The Ethical Problems in Relations of Business to Government, New Kork, NY: T h e Ronald Press Co. 17. McDonald, Gael M. and Zepp, Raymond A. (1789), “Business Ethics: Practical Proposals,” Journal of Management Development, 8(1), 55-66. 18. Murphy, Patrick E. (1988), “Implementing Business Ethics,” Journal of Business Ethics, December, 907-15. 19. Parry, J o h n (1988), “Direct Marketing: Marketers Q u e u e Up to Race Through Freer Europe,” Advertising Age, October 17, S6, S8. 20. Raelin. Joseph A. (1987), “The Professional as the Executive’s Aide-de Camp,” Academy of Management Executive, August, 171-82. 21. Sisodia, Rajendra S. (1990) “We Need Zero Tolerance Toward Ethics Violations,” Marketing News, March 5, p. 4. 22. van Dam, Laura (1785>, “Corporate Ethicists Put a New Dimension in Corporate Strategies,” New England Business, November 18, 36,39. 23. Wallace, Doug a n d White, Julie Belle (1988), “Building Integrity in Organizations,” New Management, Summer, 30-35. 24. Wulfemeyer, K. Tim (1990>,“The Radio-TVNews Direcrors’ Association’s Code of Broadcast Ethics: A Critical Analysis of Support for the Code Among News Directors,” Ethics in America, Proceedings of t h e National Conference o n Ethics in America, Long Beach, CA, January, pp. 1-12.

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