Implementation and Development of an Ethics and Compliance Program: A Middle Management Perspective (WITHDRAWN).

This paper examines how middle managers experienced the implementation and development of an ethics and compliance program. Based on semi-structured interviews and archival data, it shows how the program evolved in a context of regulatory reform and intense stakeholder pressure in Brazil. In 2015, the program was characterized by a coercive environment featuring strict rules and procedures, internal investigations, and an unprecedented sanctioning system. It was consolidated through major changes in key organizational processes, especially centralization of procurement processes and segregation of duties. In 2019, middle managers experienced a new phase in the program's development, characterized by an approach that advocated the moral development of employees. This paper argues that middle managers play three roles in the development of an ethics and compliance program under intense stakeholder pressure--pathfinder, investigator, and promoter. It contributes to a better understanding of ethics and compliance programs as dynamic processes and to the roles played by middle management in their development. [ABSTRACT FROM AUTHOR]