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2591-2259 / This is an open access article under the CC-BY-SA license https://creativecommons.org/licenses/by-sa/4.0/
DOI: 10.17573/cepar.2025.1.03 1.01 Original scientific article
Civil Service Ethics in Germany from  
an International Perspective – Between 
a Role Model and Latecomer
Christoph Demmke
University of Vaasa, Finland
christoph.demmke@uwasa.fi
https://orcid.org/0000-0001-6589-3127
Received: 26. 2. 2025
Revised: 21. 4. 2025
Accepted: 7. 5. 2025
Published: 20. 5. 2025
ABSTRACT
Purpose: The article evaluates how civil-service ethics are institutional-
ised and managed at federal level in Germany, and situates German prac-
tice within a broader European perspective. It addresses the conspicuous 
absence of empirical evidence on the effectiveness of ethics policies, de-
spite the proliferation of governance indices.
Design/Methodology/Approach: The analysis draws on a 2025 EU survey 
on ethics policies in central public administrations. Twenty-six countries 
and all EU institutions contributed data, completing a seven-chapter, 
59-question survey that covered rules, implementation, enforcement and 
emerging issues such as artificial-intelligence-related risks. Germany’s re-
sponses are examined in detail and juxtaposed with international bench-
marks for corruption, rule of law, good governance and impartiality.
Findings: Germany retains many “classical” bureaucratic features—life-
time tenure, hierarchical structures and a rule-oriented culture—yet 
scores consistently well on cross-national governance indicators. Frag-
mented responsibility and limited monitoring mean that hard evidence 
on policy effectiveness remains scarce, both in Germany and elsewhere. 
Nonetheless, the German system appears to deter misconduct effec-
tively when compared with its European peers. New challenges linked to 
artificial intelligence, disclosure of interests and revolving-door move-
ments are recognised, but comprehensive data and coordinated over-
sight mechanisms are still lacking.
Academic contribution to the field: The study provides one of the first 
systematic, data-driven assessments of civil-service ethics in Germany 
and enlarges the comparative evidence base for public-sector integrity 
research. It exposes methodological gaps in measuring ethics outcomes 
and underscores the need for interdisciplinary approaches that integrate 
legal, organisational and behavioural perspectives.
Originality/Significance/Value: By combining a rare national case study 
with a unique EU-wide dataset, the article challenges the assumption that 
Demmke, C. (2025). Civil Service Ethics in Germany from an International Perspective 
– Between a Role Model and Latecomer. 
Central European Public Administration Review, 23(1), pp. 63–98

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Christoph Demmke
traditional, compliance-based systems are inherently obsolete. It demon-
strates that Germany’s ostensibly old-fashioned model performs robustly 
in practice, while highlighting structural and informational deficits that 
must be addressed if ethics policies are to keep pace with technological 
and organisational change.
Keywords: civil service, ethics, innovation in public administration
Etika javne službe v Nemčiji z mednarodnega vidika – med 
vzornikom in zamudnikom
POVZETEK
Namen: Članek ovrednoti, kako je etika javnih uslužbencev institucional-
izirana in upravljana na zvezni ravni v Nemčiji ter nemško prakso umešča 
v širši evropski kontekst. Obravnava očitno pomanjkanje empiričnih do-
kazov o učinkovitosti etičnih politik kljub množici kazalnikov upravljanja.
Zasnova/metodologija/pristop: Analiza temelji na anketi iz leta 2025, ki 
jo je podprla EU in je obravnavala etične politike v osrednjih javnih upra-
vah. Sodelovalo je šestindvajset držav in vse institucije EU, ki so izpolnile 
vprašalnik s sedmimi poglavji in z 59 vprašanji, ki je zajemal pravila, izva-
janje, izvrševanje ter nova vprašanja, kot so tveganja, povezana z ume-
tno inteligenco. Nemški odgovori so podrobno analizirani in primerjani z 
mednarodnimi merili za korupcijo, vladavino prava, dobro upravljanje in 
nepristranskost.
Ugotovitve: Nemčija ohranja številne »klasične« birokratske značilnosti 
– zaposlitev za nedoločen čas, hierarhične strukture in k pravilom usmer-
jeno kulturo – vendar pri mednarodnih kazalnikih upravljanja dosledno 
dosega visoke ocene. Razdrobljena odgovornost in omejeno spremljanje 
pomenita, da trdni dokazi o učinkovitosti politik ostajajo redki, tako v 
Nemčiji kot tudi drugje. Kljub temu se zdi, da nemški sistem v primerjavi z 
evropskimi primerljivimi sistemi učinkovito odvrača od neustreznega rav-
nanja. Priznani so novi izzivi, povezani z umetno inteligenco, razkritjem 
interesov ter prehodi med javnim in zasebnim sektorjem, vendar celoviti 
podatki in usklajeni nadzorni mehanizmi še vedno manjkajo.
Akademski prispevek k področju: Študija je ena prvih sistematičnih, na 
podatkih utemeljenih vrednotenj etike javnih uslužbencev v Nemčiji in 
razširja primerjalno bazo dokazov za raziskave integritete v javnem sek-
torju. Razkriva metodološke vrzeli pri merjenju etičnih rezultatov ter 
poudarja potrebo po interdisciplinarnih pristopih, ki združujejo pravne, 
organizacijske in vedenjske vidike.
Izvirnost/pomen/vrednost: Z združitvijo redke nacionalne študije prime-
ra z edinstvenim naborom podatkov EU članek izpodbija predpostavko, 
da so tradicionalni, na skladnosti utemeljeni sistemi po svoji naravi zasta-
reli. Pokaže, da se navidezno staromodni nemški model v praksi izkaže 
kot zelo učinkovit, hkrati pa poudari strukturne in informacijske pomanj-
kljivosti, ki jih je treba odpraviti, če želijo etične politike slediti tehnolo-
škim in organizacijskim spremembam.
Ključne besede: državna uprava, etika, inovacije v javni upravi
JEL: H11, H83

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1 Introduction
Overall, the effectiveness of ethics policies and ethics management is under-
researched. Grand exceptions concern Mackenzie (2002) and Anechiarico and 
Jacobs (1996) in the US and in Canada and Demmke and Moilanen (2012) in 
the European Union. The highly critical study by Mackenzie (2002) concludes: 
“Is there more integrity in government today than there was before 1961? No 
one knows because no one can measure what cannot be observed” (Macken-
zie, 2002, p. 150). Anechairico and Jacobs noted that “the public standard of 
morality has become much stricter, and the gap between the mythical system 
and the operating system much wider. Previously accepted conduct (...) is now 
deemed unethical, and previously unethical conduct is now deemed crimi-
nal...” (Anechiarico and Jacobs, 1996, 16). Demmke and Moilanen (2012) are 
less sceptical but conclude that ethics policies produce several side-effects, 
unintentional effects, and paradoxes. In the field of corruption, Johnston and 
Fritzen (2021) note: “We know far more about the issue than we did 30 years 
ago, and we have a network of policies, organizations, and researchers on a 
scale, and level of sophistication, few could have imagined in those earlier days 
(...). Still, most reforms have met stiff headwinds (for evidence suggesting that 
most countries have made little or no progress against corruption over the 
last 20 years...” (Johnston and Fritzen (2021, p. 5)). Also, in other policies, for 
example in the field of conflicts of interest, Peters and Handschin (Peters and 
Handschin, 2012) discuss trends towards the widening of the concept of con-
flicts of interest and the blurring of the concept with the notion of conflicting 
interests. Whereas in the past, the concept of conflict of interest focused on 
financial interests and how these could lead to a conflict between profession-
al and private interests, today, all sorts of financial and non-financial interests, 
value conflicts, and role conflicts are discussed under the label of conflict of 
interest. As a consequence of the constant widening of the concept, it is im-
possible to assess the effectiveness of the concept. Similar methodological 
challenges exist as regards the concepts of (sexual) harassment, bullying, and 
anti-discrimination. Almost all researchers criticize the lack of data as a sore 
point in the research. Also, in our study, including Germany, many countries 
noted: There is no data, information, or research available on this.
2 Methodology
2.1 Ethics Policies in Central Public Administration
The purpose of the study is to compare and analyze the effectiveness of ex-
isting rules, policies, instruments, and the management of ethics policies in 
central public administrations in Europe. Moreover, the study takes an inter-
est in how the national central public administrations respond to new ethical 
challenges arising from public administrative reform and innovation, with a 
focus on the link between the introduction of artificial intelligence in central 
public administrations and the management of ethical challenges.

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As such, there exists no commonly agreed-upon definition of key concepts 
such as public sector, public services, civil services, and public administration, 
not to mention ‘central’ public administration (Sommermann, Krzywon and 
Fraenkel-Haeberle (eds.), 2025). This absence is problematic when compar-
ing distinct public administrative systems, civil services, public institutions, or 
when addressing central public administration from a sectoral (government, 
education, health) or functional (central, regional, local) approach
Without entering into a lengthy discussion about the pros and cons of the 
various definitions and concepts, we have decided to define central public ad-
ministration as excluding deconcentrated government levels at the regional 
and local. However, central public administration can include agencies and 
public service bodies supervised by the central government, but depending 
on the country’s definition (thus, Sweden would exclude the situation of the 
Swedish independent agencies for this study).
The choice for Germany as a case study has to do with the fact that very little 
research and evidence exist about ethics policies in the German public sector 
(Sommermann, 1998; Behncke, 2005 and 2005; Faust, 2008). If so, literature 
focuses on corruption Wolf, 2013; Wolf and Meyer, 2025).
Thus, our research suggests a re-opening of the debate about effective ethics 
policies (and, also, about German ethics policies)
2.2 Effectiveness as Goal Achievement – Focusing on the 
Prevention of Unethical Conduct
In the study, we decided to restrict our research interest to the study of goal 
achievement. As regards ethics policies, this means that we were mostly in-
terested in finding out whether and how ethics policies contribute to the pre-
vention (and reduction) of the different forms of unethical behavior.
This approach requires us to define unethical behavior. Here, various concepts 
exist, ranging from insidious behavior, unethical work behavior, and harmful 
behavior to unethical behavior (Giacolone and Promislo, 2013). Despite this 
existing variety of concepts (and the constantly evolving definitions), the con-
cept of unethical behavior is the most commonly used on the international 
level. Here, the definitions by Lasthuizen, Huberts and Heres (2011) and by 
Huberts and Lasthuizen (2014) are widely accepted. Therefore, we have de-
cided to use the following definition.
1. Corruption: Misuse of (public) power for private gain: asking, offering, 
and accepting bribes
2. Favoritism: Decision-making and use of authority/position to favor family 
(nepotism), friends (cronyism), or party (patronage) – violation of merit-
-based principles
3. Fraud and theft of resources: Improper private gain acquired from the 
organization or colleagues and citizens

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4. Conflict of (private and public) financial interest: Such as gifts, sideline 
activities, assets, or other financial interests the interference (or potential 
interference) of personal interest with the public/organizational interest 
because of gifts, services, assets, or promises taken
5. Conflict of (private and public) non-financial interest: Through job mobi-
lity (revolving door), professional activities, affiliations, memberships or 
other activities practiced outside the organization
6. Improper use of authority: The use of illegal/unethical means or methods 
to achieve organizational goals (sometimes for ‘noble causes’), like sur-
veillance, intrusion into privacy, control
7. Misuse and manipulation of information: Data and internet the intended or 
unintended abuse of (access to) online information, such as hate speech, 
internet aggression, disinformation, shit storms, violation of secrecy rules, 
breaching the confidentiality of information, or concealing information
8. Indecent treatment of colleagues, politicians, or citizens: Unacceptable 
treatment such as discrimination (based on gender, race, or sexual orien-
tation), intimidation, sexual harassment, improper behavior like bullying 
(protection of personal dignity, vulnerabilities)
9. Waste and abuse of organizational resources: Failure to comply with orga-
nizational standards
10. Misconduct in private time: Conduct during private time that harms 
people’s trust in the (public) organization
This definition by Lasthuizen, Huberts and Heres (2011) and Huberts and Last-
huizen (2014) was slightly adapted by the author to consider the most recent 
developments in the field of artificial intelligence and misinformation, fake 
information, and so-called post-truth (Farkas and Schou, 2024).
These types of unethical behavior occur at any time, place, and in all coun-
tries. Also, the definition of unethical behavior is understood in all languages 
and administrative cultures.
2.3 Research Questions
The study focused on civil service ethics (statutory staff and staff with a pub-
lic law status) in the central public administrations. However, some countries 
(who do not apply status differences or differences in the field of public eth-
ics for civil servants and public employees) focused on public employees on 
the central public administration level, or on
Our main research questions in this survey were the following:
1. What do we know about the effectiveness of ethics policies as regards une-
thical outcomes such as corruption, fraud, conflicts of interest, bullying, 
(sexual) harassment, and other forms of unethical (workplace) behavior 
(definition Leo Huberts et al.)?

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2. What do we know about the effectiveness of individual ethics policies such 
as revolving door, disclosure policies, whistleblowing policies, and anti-di-
scrimination policies?
3. What do we know about the effectiveness of instruments used in the field, 
such as ethical leadership, rules, codes of ethics, training, enforcement, be-
havioral instruments…?
4. What do we know about the effectiveness of ethics management and the 
institutionalization of ethics policies, such as centralization/decentralizati-
on, self-regulation/management vs. independent management, and coor-
dination amongst ethics bodies?
5. What do we know about the effectiveness of measuring ethics policies 
(measuring corruption, measuring conflicts of interest, measuring haras-
sment, etc.)?
6. What do we know about innovation/change processes of governance and 
public administration, and the impact on ethics and unethical behavior, 
such as outsourcing, public-private partnerships (PPP), collaborative forms 
of governance, and artificial intelligence?
While all six research questions merit being treated equally in our analysis, 
neither time nor resources have allowed us to study all of these elements in 
full detail. We suggest that further research is needed to investigate in more 
detail all of these issues.
2.4 Survey Methodology and Shortcomings of the Study
As already mentioned, the survey contained seven chapters and 59 questions. 
In the survey, central public administrations and the various responsible eth-
ics bodies were asked to provide information, ranging from questions about 
the effectiveness of rules and instruments, the institutionalization of policies, 
the implementation and enforcement of ethics policies, and more forward-
looking questions about how countries and institutions address new ethical 
challenges, e.g. arising from the introduction of artificial intelligence in the 
central public administrations. Overall, most countries answered most ques-
tions, but to a lesser extent, as regards questions regarding the effects of ar-
tificial intelligence. As regards the latter, Germany answered to all questions.
Overall, in this study, not only the availability of data but also the quality of 
data was a sore point in the development of this comparative work. In our sur-
vey, this mainly concerned open questions about the impact of administrative 
reforms and the introduction of artificial intelligence, and the effects on ethi-
cal challenges. Of course, some countries could not answer all survey ques-
tions. We also noted that, despite the intensive work of the OECD in the field 
of integrity indicators, overall, data about the effectiveness of ethics policies 
is scarce, and it is also vulnerable to change and manipulation. For example, 
Germany noted that the most pressing monitoring challenge in the field of 
disclosure policies is the lack of information.

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Here, we should add that the sending of the survey to respondents in the na-
tional central administrations means that we followed partly the tradition of 
elite studies. Respondents were higher officials who were supposed to pro-
vide official data and factual information that did not reflect personal opin-
ions. These respondents were asked to further distribute the survey to ex-
perts and the competent ethics and AI bodies. Also, the German respondents 
coordinated internally within the Ministry of the Interior in order to respond 
sufficiently to the various questions. Thus, in this type of administrative elite 
studies, top officials are members of organizations with expected higher reli-
ability, institutional knowledge, and experience. Despite this, we took note 
that some questions in our survey were answered rather on an individual ba-
sis. In one case, the official country’s answer was “distorted” and not accepted 
by the research team. In other cases, it was not always possible to check which 
questions in the survey were answered in a personal capacity or influenced by 
other subjective (and political) considerations. Experience with this type of 
survey shows that official responses to empirical surveys differ according to 
the choice of the target groups. For example, top leaders respond differently 
from middle managers, and middle managers respond differently to technical 
staff. Also, official sources differ from academic sources.
We acknowledge that the responses in our survey represent official govern-
ment sources and that answers to the survey necessarily differ if we had col-
lected perception samples or from citizens.
We also opted for the possibility for countries to comment on each question. 
This type of allowing for open comments should allow the countries to dis-
cuss the questions internally and in a coordinated way, and provide opportu-
nities to better explain the national context.
Therefore, in this survey, we acknowledge the danger of significant sources of 
bias. Official respondents to the survey may have had an interest in reporting 
favorable outcomes to present a positive and successful image on the interna-
tional scene. As such, it is difficult to assess the quality of national answers to 
the survey questionnaire. However, we took note that whereas countries in-
vested a lot of (coordination) time and work before answering this survey, oth-
er countries responded in an ad hoc manner and consulted fewer colleagues, 
ethics experts, and ethics bodies before replying to the survey.
In carrying out this study, it also became evident that there can be too little 
or too much attention on theoretical issues, too little or too much focus on 
historical explanations, or a too general analysis without taking into consid-
eration the many existing specific features of the national systems, avoidance 
of different linguistic meanings and definitions, etc. Moreover, the existing 
national arrangements are in a constant process of change, and it seems that 
change is happening at ever faster speeds. If decades ago, public administra-
tion and politics were synonyms for stability, today, it is a symbol for hasty 
change, especially in the field of artificial intelligence. Parallel to this, ethics 
management is a very young discipline, both in the private and even more in 
the public sector.

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In this study, we noted that, overall, studying the effectiveness of ethics man-
agement requires an interdisciplinary and integrative approach. In the case of 
Germany, this means that only questions about corruption, fraud, and civil ser-
vice ethics are the sole responsibility of the German Ministry of the Interior. 
Other issues, like conflicts of interest, anti-discrimination and bullying (and 
harassment) also fall into the responsibility of other administrations. Contrary 
to this, the implementation logic in the national administrations follows a so-
called silo-approach. Whereas corruption, conflicts of interest, harassment, 
abuse of power, misconduct, discrimination, etc., are different forms of un-
ethical behavior, they are all dealt with in a sectoral and fragmented logic. This, 
however, is an international phenomenon (and not only typical for Germany).
While analyzing the existing data, we took note that the concept of the ef-
fectiveness of ethics policies is highly contingent. It cannot be explained 
without considering the environmental legal, political, economic and cultur-
al dimensions within the different countries. This makes research even more 
complicated. Whereas all experts commonly agree that ethics policies and 
ethics management cannot be effective as stand-alone policies (and must 
be integrated into other management logics and governance styles), this 
highly important insight is making research highly complex. Take only the 
case of state capture by influential super-rich people, companies, or politi-
cal groups. In times of growing state capture and conflicting interests, it is 
unlikely that corruption and conflicts of interests can be reduced more ef-
fectively (David-Barrett, 2023).
In this study, we focus on the institutionalization and the management of eth-
ics policies in the (German) central public administration.
Here, our data illustrates that the effectiveness of ethics policies requires bet-
ter coordination, integration and communication, as ethics policies are man-
aged by different authorities, agencies, administrative units, and persons. 
The institutional landscape is highly fragmented. Most countries criticize that 
ever more ethics bodies are taking on ever more tasks. In the national cen-
tral public administration, the (seemingly) integrated term “ethics policies” or 
“integrity policies” meets a highly decentralized and fragmented institutional 
landscape. In our survey, this is also confirmed by Germany. Often, the alloca-
tion of responsibilities and competences follows a so-called silo-thinking logic 
in the national public administrations. In the field of ethics policies, often, dif-
ferent institutions, organisations, agencies, committees, or HR offices are re-
sponsible for different policies. For example, corruption policies may be man-
aged by ministries or specialized agencies, but conflicts of interest by auditing 
offices or human resource management offices. Moreover, organisations (or 
HR offices) have a high degree of autonomy in how to manage certain ethics 
policies, like for example revolving door policies, diversity policies, or disclo-
sure policies. As regards the latter, these policies fall under the autonomy 
of each (organizational) employer. Especially, in more decentralized countries 
like Germany, Sweden, or Denmark, internal coordination challenges were ex-
tremely challenging. Some countries even responded that they would not be 

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ready, nor entitled, to respond for other administrations or organizations. As 
it turned out, in some cases, responsibilities in the field of public ethics are 
not only decentralized but also individualized. Every ministry, or every agency, 
pursues its own policies and adopts its own instruments. Thus, even if a huge 
number of public authorities contributed to this survey, this does not mean 
that we are able to present a full and coherent picture of the situation in cen-
tral public administrations in all countries. Take the case of a more centralized 
country like France, which also reported that ethics and integrity is a shared 
responsibility between the Directorate General for Public Administration and 
the Civil Service (DGAFP), the High Authority for the transparency of the pub-
lic life (HATVP), and the French anticorruption agency (AFA).
We therefore (and differently from the OECD) refrained from benchmarking 
countries, or ranking and rating countries.
Next to the coordination challenge, the most important challenge concerned 
access to reliable data about the various survey questions. The author of this 
EU study carefully avoided any overlap with other studies carried out by the 
OECD or the Council of Europe/GRECO. Instead, the objective was to generate 
new data and avoid double-work for the central public administrations. In our 
EU study, we noted that not only the availability of data, but also the reliabil-
ity of data was a sore point in the development of this comparative work. We 
also noted that, despite the intensive work of the OECD in the field of integ-
rity indicators, overall, data about the effectiveness of ethics policies is scarce, 
and it is also vulnerable to change and manipulation. We, therefore, decided 
to refrain from benchmarking countries and not to rank or rate national data. 
Instead, we opted for a comparative presentation of national answers to the 
various policies and topical issues. More concretely, this means that we reject 
any approach that compares a state-centric German “performance” with any 
other state-centric “performance” (in the field of civil service ethics).
3 Defining Ethics Management and the Institutionalization 
of Ethics Policies in Europe
Research on anti-corruption strategies and institutions (Marčetić, Džinić and 
Manojlović, 2020), national and local integrity systems (Huberts et al., 2008), 
organizational integrity (Kaptein, 2024), and on specific integrity measures 
has resulted in many suggestions about what elements, components, or 
measures are needed that will enable organisations to achieve more ethi-
cality (Hoekstra, Huberts and van Montfort, 2022; Huberts, 2014). Overall, 
experts distinguish between ethics management and organizational integ-
rity, although the boundaries between both concepts are rather unclear. In 
this respect, ethics management can be described as the sum of consistent 
(systemic) efforts of an organization focused on promoting ethical behavior 
(integrity) (Hoekstra, Huberts and Gaisbauer, 2016, p. 16; Kaptein, 1998) or 
as the activities undertaken to stimulate and enforce ethical behaviour and 
integrity and prevent corruption and other integrity violations within a par-
ticular organization (Maesschalck and Bertok, 2008).

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As regards the public sector, much of the literature assumes that the compo-
nents of ethics management systems are universally applicable (OECD, 2020). 
For example, according to Huberts (2014), it is possible to stress the “basics 
of an integrity system”. Suggested instruments include the existence of rules, 
disciplinary policies, the setting of ethical standards, the adoption of codes 
of ethics and codes of standards, the introduction of an active value manage-
ment policy, ethical leadership, effective whistleblowing opportunities, job 
rotation, risk analysis, training, integrity plans, integrity monitoring, scandal 
management, registers and disclosure policies, ethical climate surveys, self-
assessments, integrity officers, ethics committees and good working condi-
tions. Alternatively, Kaptein´s concept (2015) distinguishes amongst nine 
elements: a code of ethics, an integrity office (or officer), ethics training, an 
ethics hotline, the existence of accountability policies, oversight and monitor-
ing, and conflicts of interest screening.
Next to these recommended ingredients of ethics management systems, the 
concept of organisational integrity is more complex and has many definitions, 
interpretations, forms, layers, and dimensions, and it contains many perspec-
tives and ideas. According to Kaptein et al. (2024), organisational integrity is 
a multifaceted and inexhaustible subject to study because it can be explored 
in many ways and constantly leads to new insights” (Kaptein, 2024, p. 1). Ka-
ptein’s “Research Handbook on Organisational Integrity” (2024) is, by itself, a 
great testimony of how research in the field has advanced.
Organisational Integrity is being examined from different perspectives, such 
as a virtue ethics perspective, a regulatory perspective, an institutional per-
spective, or a corporate governance perspective. There also exists a strong 
disciplinary influence from related concepts in the private sector like business 
ethics, compliance, corporate citizenship, corporate social performance (CSP), 
purpose driven management, value management, corporate social responsi-
bility (CSR), corporate social responsiveness, responsible management, and 
sustainability (Trevino, L.K. and Brown, 2004; Windsor, in Kaptein et al, 2024).
Still, both ethics management and organisational theories are influenced by 
developments in the private sector. They are also highly inward-looking and 
focus on “ethics management”, instead of considering evidence from related 
fields like Human Resource Management or Organisational Behavior. Dys-
functions of ethics management systems are often explained by the fact that 
organisations have not yet fully implemented the menu of proposed com-
ponents, elements and instruments, as discussed above (take, as example, 
Hoekstra, Huberts and von Montfort, 2023) about the evaluation of integrity 
systems in the Netherlands, Belgium and Germany). Thus, whereas research 
about organisational integrity and ethics management in the public sector is 
strongly improving (Kaptein (Ed.), 2024), many fields are still widely under-
researched. For example, despite the introduction of the abovementioned 
universal components of an ethics management system, how to explain the 
huge variation of responses as regards national responses to the major ob-
stacles and difficulties for an effective policy in the field of civil service ethics.

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Table 1: Overall, what are the major obstacles and difficulties for  
an effective policy in your national civil service? N=24
 
Source: Author’s own.
At the same time, little is known about “real life”, e.g., how European countries 
organize and manage ethics policies. One exception is a study by Marčetić, 
Džinić and Manojlović for the Croatian EU-Presidency (2020) that focused on 
codes of ethics, ethics bodies, and an analysis of the existing legal frameworks 
(Marčetić, Džinić and Manojlović, 2020, p. 1). The study concludes that Eu-
ropean public administrations should (especially) work on continuous educa-
tion and application of soft law mechanisms in the field of ethics, networking, 
and cooperation with other countries, the development of an administra-
tive culture based on high levels of ethical standards, learning from own and 
other countries’ experience and keeping good communication with citizens” 
(Marčetić, Džinić and Manojlović, 2020, p. 27).
Also, little is known whether certain types of governance models, or adminis-
trative traditions, prefer certain ethics management models, or prefer certain 
instruments more than others. It also remains unclear how a coherent and 
systematic integrity approach fits into different organizational cultures, more 
or less politicized systems, or systems with more or less resources. Finally, 
little is known as regards institutional differences in managing ethics policies 
(like anti-corruption, conflicts of interest, and anti-discrimination policies), 
monitoring policies (like the monitoring of disclosure policies, or revolving 
door policies), and in the enforcement of policies (who takes responsibility in 
sanctioning misconduct?). Finally, how to interpret the different meanings of 
the same ethical concepts in different organizational cultures, like, for exam-
ple, the meaning and importance of whistleblowing.
Throughout our comparative work, we could confirm the existence of a (sur-
prisingly) huge variation of ethics management structures and practices. To 
start with: Ethics policies and ethics management do not only differ amongst 
the executive, legislative and judiciary sectors but also within sectors, (inde-

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pendent) agencies, amongst categories of employment statuses (civil serv-
ants and public employees), categories of Holders of public Office (Ministers, 
Secretaries of State, Presidents of Courts, Banks etc.) and other categories 
of staff like Special Advisors, Directors-General and top-and middle level civil 
servants. To this should be added great differences on the sub-national level 
(Lapuente and Dijkstra, 2012, pp. 68–90).
On the central level, some countries have relatively centralized management 
systems (like Romania with the General Anti-corruption Directorate (DGA) 
the National Integrity Agency (ANI) (which is, exclusively responsible for dis-
closure policies), Latvia with the Corruption Prevention and Combating Bu-
reau – KNAB, or France (where ethics and integrity is a shared responsibil-
ity between the Directorate General for Public Administration and the Civil 
Service (DGAFP), the High Authority for the transparency of the public life 
(HATVP), and the French anticorruption agency (AFA). Compared to France, 
the Dutch model can be defined as a hybrid integrity model, at least with 
some forms of centralized management and monitoring. However, since the 
Netherlands is a decentralized unitary state (and the public sector is divided 
into sectors), the levels of government have considerable freedom in the de-
sign of their policies. A case for a deconcentrated model is the Danish (but 
also the Swedish) model. In the central public administration in Denmark, 
the management of integrity policies is at the discretion of each individual 
employer (there exists no central employer for government employees in 
Denmark or a central institution that monitors or is responsible for anti-
corruption measures for government employees, etc.). It is therefore up to 
the individual employer to assess the employee’s behaviour and determine 
sanctions within the applicable rules. If the employee’s behaviour violates 
the rules of the Danish Criminal Code, the responsibility lies with the police 
and the public prosecutor. In Denmark, there are no rules regarding ‘revolv-
ing door’ and ‘non-financial conflict of interest’ for government employees. 
Instead, it is the individual employer that is responsible for compliance with 
the guidelines, etc., as there are no such rules for public employees in Den-
mark. Also, in the field of disclosure policies, there are no central monitoring 
bodies in Denmark that monitor the above-mentioned interests of govern-
ment employees. The Responsibility for ensuring compliance with applicable 
rules and guidelines lies with the individual employer. This, again, contrasts 
with the situation in Germany, where responsibilities for the federal level are 
vested in the German Ministry of the Interior.
Interestingly, all Scandinavian and northern states (Estonia, Sweden, Den-
mark, Finland and Estonia) have highly deconcentrated models. In these 
countries, each ministry manages ethics policies like revolving door and dis-
closure policies on its own. Also, disclosure policies are managed “individu-
ally”. Likewise, these countries do not monitor ethics policies on a central 
level. All of these countries found it difficult to provide general answers to 
our survey. In the latter case, this does not only mean that no centralized 
rules exist on how to disclose interests, which interests, how to verify dis-
closure requirements, and how to sanction the violations of policy require-

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ments. In fact, this also means that ethics policies are not monitored and no 
cost assessments exists on the central level. Therefore, a standard answer 
from northern countries to our survey was the following: “The effectiveness 
is not measured and we do therefore not have data to support a conclusion. 
Therefore, we cannot answer the question”.
Similar “differentiation” trends can also be seen in the enforcement of ethics 
policies. Also, in this field, it would be wrong to assume that enforcement is 
only carried out by the judiciary and the police. In reality, enforcing miscon-
duct has become the responsibility of a variety of organizations (and also a 
leadership responsibility). Overall, HR offices play a widely underestimated 
role in the monitoring (and enforcement) of ethics policies. Partly, HR offices 
also monitor and enforce side activities and gift policies for different catego-
ries of staff. However, it also happens frequently that different HR offices 
and HR officials in different ministries and agencies monitor revolving door 
policies, side-activities, and gift policies, although these issues relate to each 
other and should be managed within the same organization and office.
Thus, this great diversity of systems in Europe raises the question whether 
it is possible to classify national systems into typologies or to develop state-
centric benchmarking models. As such, we note that, in all countries, monitor-
ing practices, monitoring evidence, data, and measurement differ, sometimes 
from one organization to the next. Also, the choice of policy instruments is 
pluralist, non-deterministic, and flexible, and varies from one country to the 
next, from one institution to the next, and from one policy to the next. Here, 
there is no logic. For example, it is impossible to state that more bureaucratic, 
or countries with (rather) classical career systems, have also chosen a more 
centralized or decentralized approach in the field of ethics management. 
Likewise, it is impossible to state that, for example, revolving door policies are 
managed according to a specific public management or organizational model. 
Overall, most European countries agree that the institutionalization of ethics 
policies is highly fragmented and ineffective, especially in related policies like 
the management of side-activities, revolving door, and gift policies.
In addition, we note European-wide trends towards the proliferation of eth-
ics bodies and ethics actors, but also the emergence of a great variety of 
administrative bodies and organisations, and no development towards one 
best-practice innovative organizational model. Therefore, most likely, the cur-
rent trend is not toward one best-practice organizational model but rather to-
wards a hybridization and differentiation of various ethics management sys-
tems. This also means that it is very difficult to determine the effectiveness 
of one national system by comparing it to another national system. Still, this 
does not mean, of course, that countries could benefit greatly if they were in-
terested in exchanging experience, for example, as regards the management 
of revolving door policies.

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Table 2: In the field of related policies, such as the management of gift  
policies, revolving door policies, and disclosure of (financial),  
administrative responsibilities are shared and fragmented, N=26
 
Source: Author’s own.
Of course, it is hugely tempting to engage in the benchmarking of countries 
or even to rate and to rank countries, as regards certain ethics policies, instru-
ments, processes, or procedures. However, after carefully studying the highly 
different institutionalization of ethics policies and the varying distribution of 
internal responsibilities, we have decided to refrain from benchmarking, rank-
ing, and rating of countries.
In our EU study, countries responded that they have progressed in the field of 
measuring corruption, but not very much in other fields. They have no over-
view of the costs of ethics policies. Finally, politicians and public servants are 
not aware of the monitoring challenges of those who need to monitor disclo-
sure policies. Overall, there seems to be very little communication amongst 
the (mostly HR) experts who are in charge of monitoring top civil servants. It 
is, therefore, not surprising that 73% of respondents to our study replied that 
they are not aware of (increasing) difficulties and technical challenges in the 
monitoring process. Also, in Germany, there exist no assessments about the 
costs (and benefits) of ethics policies on the federal level. Likewise, conflicts 
of interest policies are not monitored. Until today, there exist no studies or 
assessments about the monitoring of disclosure of interest policies (and the 
enforcement of these policies). If so, statistics are (sporadically) established in 
the various sub-fields, like in the field of revolving door policies.
Therefore, ethics policies present a huge paradox: For example, if disclosure 
policies are supposed to be effective, the management and monitoring re-
quire capacities, skills, personnel resources, and sophisticated and complex 
examinations into personal behavior (take the discussed case of requiring dis-
closure information from the “spouse”). If current trends have been towards 
more detailedness and individualization of monitoring requirements, this will 
also increase administrative burdens, complexity, and time-consuming moni-
toring processes.

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Table 3: In the field of disclosure policies, do monitoring experts in your 
country report about increasing difficulties as regards the  
verification of disclosure information? N=26
 
Source: Author’s own.
We are aware that these findings run counter to the present explosion of 
benchmarking studies, rankings and ratings, and trends towards the quantifica-
tion of governance and – even of – ever more aspects of social life (Mau, 2020).
Benchmarking studies are attractive because statistics, rankings, and ratings 
enable easy comparisons, competition, the possibility for evidence-based 
learning, and the reduction of complexity. Figures and statistics promise ob-
jectivity. They also promise the possibility for fact-based learning. At present, 
one can observe the emergence of a truly globalised world of comparisons, 
scores, rankings, likes and grades. Because of data-driven benchmarking, ever-
new rankings and ratings of various governance indicators come and go with 
remarkable rapidity, “New techniques come into fashion and old ones go out, 
much like the outfits modelled in Paris, Milan, and New York” (Aberbach and 
Rockman, 2000, p. 9). Benchmarking raises the question, which indicators and 
factors to use as the basic features for comparing policies, instruments, and 
structures? This again raises the question of whether and how some phenom-
ena can be measured at all. Finally, we need data, comparable data, good data 
and data that is based on the same definitions, reliable and accurate data. 
In our study, most countries informed us about their challenges when moni-
toring ethics policies, the non-existence of data, and the challenges when it 
comes to measuring ethics policies. We also learned about the important link 
between national administrative culture and the management of ethics poli-
cies. Should we rank some countries better than others, because they have 
centralized monitoring structures or more detailed disclosure requirements 
or stricter revolving door policies than others, (in some instances, because 
they are more reluctant in the field because of privacy and data protection is-
sues)? Should we applaud countries because they have adopted stricter legal 
requirements, introduced new ethics bodies, or have been ranked more posi-
tively in the Corruption Perception Index (CPI), or by the OECD (or by GRECO)?

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These issues constitute only a fraction of the existing challenges in the field 
of comparing and analyzing the effectiveness of ethics policies. If we ranked 
countries in top-performers or low-performers, laggards and forerunners, 
we risk basing our judgments on problematic indicators, poor data, value 
judgments, unclear assumptions, and on different definitions. Again, take 
the case of disclosure policies in the field of conflicts of interest. Today, de-
spite laudable progress in the field of corruption (United Nations Office on 
Drugs and Crime (UNODC), 2023), it remains an extraordinary undertaking 
to generate, measure, compare, and analyse data in conflicts of ethics poli-
cies. Thus, while we welcome any progress in the field of measuring integrity, 
we nonetheless remain cautious in our temptation to generate data-driven 
comparisons in fields where the quality of data is scarce, difficult to compare, 
or not yet fit for comparison. The decentralized and, often, individualized 
management of ethics policies has important implications for the quality of 
comparative and benchmarking studies and the possibility of measuring and 
monitoring ethics policies.
Consequently, the effectiveness of any particular institutional integrity sys-
tem can only be determined by the degree of consistency amongst its proper 
constituent elements, practices, procedures, instruments and resources and 
how these fit into the specific constitutional-, legal-, and political system, the 
culture, organizational design, organizational culture and leadership styles.
Given the limited space in this paper, we will focus on the case of Germany 
(within the international context) and discuss the (in-) consistency of the Ger-
man model.
4 Case Study: The Specifics of German Civil Service Ethics
In Germany, the belief is still very strong that government integrity flows from 
respecting and applying the rule of law, a public ethos, sound administration, 
classical hierarchical structures, and a very specific civil service system with life-
time tenure, full-time employment, advantageous pension systems, and the 
existence of career systems. All of these features, it is believed, are necessary 
in order to reduce as far as possible the risk of too much political influence, 
corruption, misconduct, conflicts of interest, and state capture for private in-
terests. Following this, at a minimal level, the German administration is con-
sidered to be good and ethical if it achieves the implementation and enforce-
ment of the existing civil service laws and disciplinary rules of the Government 
of the day. Moreover, ethically good or acceptable behavior is defined in terms 
of rationality, impartiality, and the application of the merit principle.
Like in so many other countries, also, in Germany, no day goes by without 
media coverage about new scandals and discussions about (im-) moral behav-
ior in the German society, in the whole public service, and, increasingly, also 
against civil servants. Often, the diagnoses for the various types of unethical 
behavior is very simplistic and depending on political attitudes to which the 
reasons are either not enough rules (and the need for stricter rules), a decline 

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or even loss of societal values, or too much of it - the moralization of the 
(political) discourse. Other experts point to the effects of increasing individu-
alization (Beck), singularization (Reckwitz), self-optimization (Bröckling, 2013; 
Röcke, 2021), acceleration (Rosa, 2005), and polarization in the German soci-
ety and their effects on the development of values. In this more nuanced, but 
also culturally pessimistic discourse, it remains unclear why values   and ethical 
standards do not continue to deteriorate and new ethical standards   continue 
to emerge. Against these trends, and when entering into the legalistic and 
technical world of the German civil service, the discussion about ethics seems 
to play a minor role. The German public sector does not pursue an active eth-
ics (integrity) policy for the public sector. Germans are highly skeptical as to 
the question whether public organisations should also pursue active moral 
policies, or any sort of purpose-driven management (Kuehl, 2021). Instead, in 
Germany, the expectation was always that civil servants would be implicitly 
ethical because they have a specific public service motivation, a specific public 
ethos, and because civil servants are different, because they are civil servants 
(Demmke, 2020). Today, this fundamental understanding of ethical behavior 
is, however, increasingly questioned (Demmke, 2019).
Still, heavily influenced by the skepticism of the German sociologist, Niklas Luh-
man, from a German point of view, the relationship between organization and 
integrity is not a love affair (Ortman, 2010). There is no perfect ethical organi-
zational recipe. And, not to forget: For many Germans, German history proves 
that both, bureaucratic blind obedience (“administrative evil”, Adams, 2011) 
and “greedy institutions” (Coser, 1974) can be abused for many unethical indi-
vidual and political interests. Therefore, German civil service ethics follows (in 
the words of Dobel, 2004) a legal-institutional model of public integrity which 
is combined with a strong sense of public service motivation and personal 
responsibility. However, the personal responsibility dimension (Dobel, 2004) 
could also be interpreted as a certain rule of law obedience. Again, the latter 
should be distinguished from blind obedience and personal irresponsibility.
However, in Germany, one can note an increasing interest in the broader con-
cept of integrity policies. One reason for this is the growing conviction that 
integrity policies “pay” (Paine, 2000), which means that an ethical organiza-
tional culture has positive side-effects on organizational and individual per-
formance, motivation, job satisfaction, teamwork, and – more generally – re-
cruitment and retention policies. Another more critical reason is that ethics 
policies are discovered (and abused) as a political weapon. Like this, ethics 
policies are instrumentalized for (un-) ethical reasons.
Therefore, the overall purpose of ethics policies is no longer seen as a purely 
intrinsic interest in the need for specific public values and principles. Instead, 
the trend is clearly towards a more utilitarian understanding and acceptance 
of ethics in Germany. More concretely, people are interested in whether and 
how ethics “pay” (Paine, 2000). Like this, the trend in Germany is no different 
than elsewhere in Europe.

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4.1 The Concept of Public Ethics and Its Acceptance in the 
German Civil Service System
Discussions about a loyal, integer, efficient, and trustworthy civil service in 
Germany are already 300 years old, or (even) as old as the existence of the 
concept of bureaucracy, as such. What is still a relatively new phenomenon 
is to use the term “public ethics” in this context (or, more recently, the term 
“integrity”). In Germany, for a long time, ethics were discussed abundantly in 
the field of philosophy (Kant) but not in public policies or in public administra-
tion. Instead, in the German civil service, civil servants are called upon to apply 
the rules, values and principles enshrined in the German Grundgesetz (Basic 
Law), the case law of the German Bundesverfassungsgericht (Federal Court 
of Justice), the Beamtendienstrecht (Civil Service Law of the Federation and 
the Bundesländer) and respect disciplinary law. Actually, Germany imported 
the term “public ethics” from Anglo-Saxon countries and, later, earlier at the 
end of the 20th century (Behncke, 2006).
Since then, the concept is interpreted in a two-dimensional way: On the one 
hand, public ethics refers to a moral dimension with regard to values, norms, 
and personal behavior. On the other hand, the term included a judicial-legal-
istic dimension with regard to laws, institutions, and controls (Behncke, 2006, 
251). According to Article 33, Paragraph 5 of the Basic Law (Grundgesetz), 
the law of the civil service must be regulated while taking into account the 
traditional principles of the professional civil service. The Federal Constitu-
tional Court defines these principles, among other things, as the performance 
principle, the loyalty principle, the duty of neutrality, and the employer’s duty 
of care. Since civil servants have a special relationship of service and loyalty 
under public law, a number of special duties are imposed on them. These ba-
sic duties include that civil servants carry out their duties impartially and fairly, 
and that they must take the public good into account when carrying out their 
duties. In addition, they must dedicate themselves to their job with full per-
sonal commitment. Their behavior on and off duty must reflect the respect 
and trust that their profession demands. This duty can also be violated if an 
official commits a crime while off duty. When carrying out their duties, they 
must always take Art 33 paragraph 5 of the German Basic Law (the public 
good) into consideration.
The civil service is for life. This is associated with the expectation that civil 
servants are less corrupt, are less influenced by conflicts of interest and are 
fully dedicated to their job. However, it has never been examined whether 
the lifetime principle (particularly in an international comparison) actually has 
these desired effects. According to Section 77 of the Federal Civil Service Act 
(BBG), civil servants commit an official offense if they culpably violate their 
duties. This is a disciplinary offense if it is a particularly serious breach of duty 
and is likely to impair trust in a way that is significant for your office or the 
reputation of the civil service. For retired civil servants, according to Section 
77 Paragraph 2 BBG, certain breaches of duty are deemed to be official mis-
conduct, e.g., activities contrary to the free democratic basic order or breach 

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of the duty of confidentiality. Disciplinary statistics collected annually (most 
recently in 2023) record the official and judicial disciplinary proceedings that 
were concluded due to a breach of official duty. The 2023 disciplinary statis-
tics concern 248,900 federal civil servants. In 2023, a total of 1,091 discipli-
nary offenses were examined for disciplinary relevance (which is a relatively 
stable figure compared to the years 2022, 2021 and 2020). Out of these, 723 
disciplinary proceedings were completed, resulting in 321 disciplinary meas-
ures being imposed. In 2023, a disciplinary measure was taken for around 
0.13% of the active federal civil servants included in the disciplinary statistics. 
The most frequently identified official misconduct concerned the unethical 
behavior of the civil servant on or off duty. This was followed by failure to 
comply with the obligation to follow official instructions from the superior 
(Federal Ministry of the Interior, Building and Community, disciplinary statis-
tics 2023, https://www.bmi.bund.de/). However, these low numbers do not 
allow any conclusion to be drawn as to whether German civil servants behave 
particularly ethically or whether the control and enforcement of breaches of 
duty is deficient. In fact, disciplinary statistics are the only way to get insight 
into the monitoring and measuring of unethical conduct. In reality, just like in 
most other European countries, Germany is not monitoring and measuring 
civil service ethics (except for criminal and disciplinary wrongdoings).
Thus, for a long time, public ethics policies primarily addressed problems of 
corruption, bribery, fraud, theft, discrimination, conflicts of private and public 
interest (through rules and policies as regards gifts, promises, jobs, activities), 
and infringement against disciplinary law. This is fairly conventional. For ex-
ample, the yearly published Integrity reports by the Federal Ministry of the 
Interior Building still focus on the fight against corruption (BMI, 2023). Com-
pared to the situation elsewhere, the term „integrity“ is used in a very narrow 
sense and means that all public employees should follow the rule of law, are 
not corrupt (commit no fraud) and take impartial decisions (“Verwaltungsin-
tegrität bedeutet, dass in Deutschland alle Beschäftigten im öffentlichen Di-
enst rechtstreu, unbestechlich und objektiv Entscheidungen treffen“) (BMI, 
2023, p. 19). Contrary to this, Huberts (2018, p. 2) distinguishes eight forms of 
integrity (ethics): wholeness and coherence, professional responsibility, mor-
al reflection, values (s) like incorruptibility, abidance to laws and rules, moral 
values and norms, and exemplary behavior.
Thus, in the German discussion about ethics and integrity, there is less atten-
tion to other forms of administrative misconduct like bullying, intimidation, 
violence, abuse and manipulation of data, algorithms and information, un-
ethical leadership, unfairness, harassment, waste of organisational resources, 
and private time misconduct.
Again, this can be explained by a fundamental feature of the German public 
administration: The separation of morality from work and the wish to main-
tain an impersonal character of organizational life. Like this, subjective and 
emotional behavior should be subordinated to the objectives of the “iron 
cage machinery” (Max Weber): German organizations are supposed to act 

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rather amoral, legalistic, standardized, and functional, and without regard to 
persons (to make it short: as impersonal and machine-like systems). However, 
this classical bureaucratic (and Weberian) understanding of civil service ethics 
should not be misinterpreted as a form of inhumane organization. Far from 
this: Internal decision-making is also highly participative, and the decentrali-
zation of responsibilities (also in an international context) relatively high. As 
such, the German administrative system is highly decentralized. According to 
Art. 79 3 Basic Law, each of the 16 German Bundesländer has its own organi-
zational prerogatives and can design its own institutional design.
4.2 The Administration and the Distribution of Responsibilities 
in Germany
Interestingly, despite its classical approach to ethics, another feature of the 
German system (notably in relation to the French, Greek, Portuguese or Ro-
manian system) is the decentralised structure and delegation of (legal) com-
petences in the field of civil service ethics.
Like most other European countries, Germany has a fragmented and decen-
tralized system based on the principles of self-regulation and self-manage-
ment. For example, suspected cases of misconduct by German ministers or 
secretaries of state can be checked and monitored by the German parlia-
ment. However, there exists no independent and external monitoring bodies 
that supervise either top civil servants or parliamentarians. There is also no 
centralized public- and civil service ethics body for all public institutions and 
bodies. Instead, in Germany, the Federal Ministry of the Interior, Building and 
Community (Division DG I 3 takes the lead on these issues) is the main coordi-
nating body for ethics policies, but only on the federal level. The Ministry also 
issues yearly reports about integrity (so-called Integritätsberichte) and over-
sees the implementation of the various anti-corruption and anti-fraud laws 
on the federal level.
It is supported in its work by other bodies and organisational structures, such 
as units responsible for internal audits and/or the prevention of corruption in 
other ministries and the Federal Chancellor’s Office, bodies responsible for 
authorising secondary employment and the acceptance of gifts and/or the 
Agency for Civil Education.
Furthermore, in accordance with the Anti-Corruption Directive, each federal 
agency (including all ministries) is required to appoint contact persons for 
corruption prevention, who can inter alia be charged with advising the man-
agement on corruption prevention issues, keeping staff members informed 
on corruption prevention matters, and monitoring and assessing any indica-
tions of corruption. Under the auspices of the Federal Ministry of the Interior, 
Building and Community, a network of contact persons across the federal 
administration would come together annually to discuss issues pertinent to 
the prevention of corruption in the federal administration. The main policy 
document in the field of civil service ethics at the federal level is the Federal 

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Government Directive concerning the Prevention of Corruption in the Fed-
eral Administration (hereafter “the Anti-Corruption Directive”). The current 
version of the Anti-Corruption Directive dates back to 2004 (with a revision 
currently being prepared by the Federal Ministry of the Interior, Building and 
Community in close consultation with all federal ministries).
The Anti-Corruption Directive prescribes inter alia that all federal agencies 
shall identify areas of activity especially vulnerable to corruption, which is to 
be followed by an assessment as to whether existing safeguards are suffi-
ciently effective to counter the risks. In addition, the Anti-Corruption Direc-
tive is said to serve as a model for the 16 Länder and to influence strategies 
of the private sector. The Anti-Corruption Directive is complemented with an 
Anti-Corruption Code of Conduct and Guidelines for supervisors and heads 
of public authorities. The Anti-Corruption Directive, Code of Conduct and 
Guidelines for supervisors and heads of public authorities are compiled in one 
brochure “Rules on Integrity” (Regelungen zur Integrität), which also contains 
further guidance to each of the provisions of the Anti-Corruption Directive 
(called recommendations for the prevention of corruption), additional circu-
lars and administrative regulations on such issues as gifts, sponsoring (etc.), 
as well as relevant excerpts of the German Criminal Code, the Freedom of 
Information Act and useful internet links.
In addition, various legal provisions (on ancillary activities and post-employ-
ment restrictions pursuant to the Act on the legal status of Federal Ministers 
and the Act on the Legal Status of Parliamentary State Secretaries) set out 
certain enforceable integrity standards. Next, the ethics of German (federal) 
civil servants, including principles and ethical leadership obligations (Fürsorge-
prinzip), are defined in the various German civil service laws.
Still, since police matters are (mostly) the responsibility of the German Länder, 
this is also the case for the implementation of anti-corruption laws and eth-
ics policies on the sub-national level. Overall, each Land has its own policies, 
strategies, and rules in the field of civil service ethics.
4.3 Towards the Choice of New Instruments, Approaches, and 
Styles
When reflecting upon the development towards ever broader conceptions 
of the term “public service ethics”, in Germany, the focus has long been on 
the adoption of more and stricter rules and sanctions, thus hard institutional 
instruments. On the one hand, also in Germany, it is accepted that bureau-
cratic organisations are often dysfunctional and people dislike organizations 
that perceive organisations and employees as machines and people as instru-
ments. Therefore, during the last decades, policies also focused on preven-
tive measures like investments in training, awareness raising, ethical leader-
ship, risk management, the introduction of the so-called four-eyes principle, 
the strengthening of internal reviews, the introduction of anti-corruption of-
ficers, and the hesitant adoption of codes of ethics.

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With this choice of instruments, Germany is fairly traditional.
Like this, we contradict the popular assumption that Germany is focusing 
exclusively on compliance-based approaches and hard instruments. In fact, 
it is widely accepted that only the combination of soft, informal, and hard ap-
proaches offers opportunities and prospects for good administrative practice 
(Faust, 2008, p. 260). In fact, this has long been recognized by the German 
Government. For example, the yearly published Integrity report lists all exist-
ing preventive measures in chapters 1.2 and 2.2. and the most important laws 
and rules in chapter 2.1.2. of the report.
This, again, means that public ethics can only be effective if there exists a 
broad menu of instruments and if ethical requirements match with other so-
cietal standards, norms, and values. Thus, even if countries have a perfect eth-
ics management system at their disposal, this does not mean that this system 
also generates the anticipated positive outcomes.
Still, as regards the question “In which fields are the most promising oppor-
tunities for innovations and effectiveness?”, Germany responded that it still 
sees great opportunities in the field of legal innovation. This contrast with 
most other countries who see the greatest opportunities in the field mana-
gerial, Artificial Intelligence, control, and persuasive instruments, but not in 
the legal field (which is perceived as not innovative) and also not in the field 
of economic innovation (because the choice of available instruments is too 
limited in this field).
Table 4: When considering the need to increase the effectiveness of ethics 
policies, in which of these fields are the most promising  
opportunities for innovations and effectiveness? N=22
 
Source: Author’s own.

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Moreover, public service policies can only be effective if there exists aware-
ness that public ethics “pays” (Paine, 2000; latest Ahluwalia, Ferrell, Ferrell and 
Gandhi, 2023) in terms of increased country, organizational, and individual per-
formance. Only then is there a chance that ethics policies are taken seriously.
Whereas in the meantime, a solid body of research exists (Mungiu-Pippidi, 
2015; Mungiu-Pippidui and Johnston, 2017; Mungiu-Pippidi, 2020; Bågenholm 
et al., 2021; Meyer-Sahling et al., 2019, 2020 and 2021) that backs up claims 
to which good governance features and ethical governance are linked to posi-
tive governance outcomes such as lower corruption levels, higher trust levels, 
enhanced organizational- and individual performance, lower sickness levels, 
higher job motivation etc. This is not yet common sense in German public life, 
where public ethics is still seen as a soft policy.
Proponents of ethics management rightly claim (for exp., OECD, 2020) that 
institutions can enhance individual- and organizational performance, promote 
honor, respect, compassion, mindfulness, tolerance and anti-discrimination.
However, as can be seen, leadership and institutions can also act exactly into 
the opposite direction: They can promote and support unethical conduct, sup-
press morality, overstretch it, deviate and transgress from accepted norms, 
and commit employees to unethical acts.
Overall, it is naive to think that ethics management also pays in a context of 
democratic backsliding, at any time and in any political context. There is a 
discernible perception that merit-based and impartiality principles are at the 
very least being less implemented and enforced (Oliveira et al., 2023). At the 
same time, populists and authoritarian leaders are popular because of their 
anti-elitist and anti-corruption agendas and because people are distrustful 
of the powerful and of politicians, political parties, and public authorities. 
Like this, anti-corruption and integrity policies are easily abused as political 
stigmatizers and against good governance policies. Overall, more politicians 
have discovered that moral talk and moral action are popular and help them 
to gain political support.
Thus, also in Germany, the present understanding of ethics seems to be para-
doxical: on the one hand, as the results of the study show, everywhere in 
Europe, there has never been so much public attention on ethics, discussions 
about the need to fight unethical behavior, moralization, and scandalization. 
On the other hand, different policies have different objectives. Ethics poli-
cies are popular, but not effectively implemented and enforced, and there is 
very little common understanding of what should be the objective: what is 
ethical behavior?
In the meantime, also inside the public service, moral and ethical standards 
are changing as rapidly as the administrative and Human Resource Manage-
ment (HRM) context. What was legal a generation ago is considered unethical 
today. Thus, the concept of ‘Integrity of Governance’ is more complex and 
“path dependent” than ever. Progress in the field is combined with new chal-
lenges, conflicts, and dilemmas. In the field of Governance, experts (Peters 

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Christoph Demmke
and Pierre, 2021; Torfing, 2023) observe trends are moving towards a “mar-
ketization of societies” (Sandel, 2012), but also towards the return of the big 
security state - Leviathan, towards flexible forms of Governance, the emer-
gence of a digitalized shared economy, and a return to ‘moral politics’ – all 
in one. To this should be added trends towards the diversification of institu-
tional systems and HRM systems.
Finally, despite ever more investments in the field of ethics management, lit-
tle is known about the effectiveness of various hard- and soft policies and 
instruments and in which institutional contexts and individual situations they 
work, or not. Despite these uncertainties, in many European countries, the 
reform of ethics policies develops into a highly specialized and professional-
ized ethics bureaucracy. Here, trends are towards ever broader and stricter 
integrity requirements. Still, our data shows that ethics policies are ineffec-
tive because of the existing shortcomings in measuring, monitoring imple-
menting integrity policies. Here, Germany is pursuing a slightly different and 
less bureaucratic path because it “trusts” heavily in the public ethos of its civil 
servants and its rule-abiding culture.
This altogether presents a highly fascinating, but also a contradictory sce-
nario. In the field of civil service ethics, there is no common trend towards a 
universal ethical administrative model. Instead, there is – differently to what 
neo-institutionalists expected – no “isomorphism” logic and no trend towards 
a best-practice model.
For example, the German model differs considerably from the French model, 
although both models can be described as rather classical bureaucratic ethics 
systems. Because of its focus on regulation and (judicial) control, the German 
model is easily dismissed and perceived as old-fashioned (Hoekstra, Huberts 
and van Montfort, 2021). Still, from a German perspective, the emerging 
ethics management systems and institutional models in other EU countries 
also do not necessarily perform better, because there is no evidence that 
corruption levels, conflicts of interest, discrimination, unethical leadership, 
bullying, or harassment would be significantly lower elsewhere. This also 
relates to the so-called forerunners in ethics policies, like the Scandinavian 
countries. While these countries perform well in the field of anticorruption, 
this cannot be confirmed in other fields of civil service ethics, like in the field 
of conflicts of interest
Still, in all countries, integrity policies, ethics management, and the monitor-
ing and measurement of ethics policies are expanding and becoming more 
complex, bureaucratic, and control-oriented. Looking at these developments, 
one could even say that the bureaucratisation of ethics policies is a global 
trend (Demmke, 2024) whereas the – so-called traditional, compliance ori-
ented and bureaucratic German ethics system is only reluctantly accepting 
the latest reform fashions in the broader field of public service ethics, like 
requirements to introduce detailed disclosure requirements or to introduce 
tough revolving door measures. This is paradoxical indeed.

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4.4 Current Reform Trends of German Ethics Policies
Also in Germany, during the past decades, trends have been towards an 
ethicalization of law and policies. Ethicalization means that ever more laws, 
regulations, and administrative provisions refer to ethical requirements and 
ethical standards. Ethics concepts have also become broader, and ethical 
standards have become stricter, especially in the field of anti-discrimination 
and conflicts of interest (Demmke et al., 2021). This is also being confirmed 
by our data: These trends can also be characterized as a self-reinforcing and 
scandal-driven logic that is highly simplistic, change-resistant and continues to 
follow the logic of requesting ever more and ever stricter laws, after scandals 
took place. Simplistic and change resistant means that it is simply impossible 
to call for a deregulation, relaxation, or differentiation of integrity policies in 
certain areas, or – sometimes – to criticize the call for more and stricter laws. 
Partly, this logic still exists today. The popular narrative is the following: More, 
stricter, wider – is the way to go.
However, scandals are rarely the only (or most important) reason (or cause) 
why countries reform and innovate ethics policies. For example, in the past, 
in many national cases, assessments and recommendations by GRECO evalua-
tions have played a role in why governments changed policies. In other cases, 
new research, evidence, or studies published by the OECD can also be influ-
ential. Again, in other countries, new case law by courts puts governments un-
der pressure to change laws and policies. Also, media attention or reports by 
watchdogs (NGO´s) are important causes and pressures for new reforms and 
innovations. In Germany, GRECO evaluations and OECD assessments are not 
well known to the public. Instead, the most important pressures for (mostly 
legal) reforms are scandals. Still it is worth noting that German policies in the 
field of public ethics strongly focus on problems of corruption, bribery, fraud, 
theft, discrimination, conflicts of private and public interest (through rules 
and policies as regards gifts, promises, jobs, activities). They are less designed 
to address other forms of misconduct. Just like most other countries, the 
German administration is reluctant to effectively monitor ethics policies or 
to measure misconduct, like conflicts of interest. Also, enforcement activities 
strongly focus on criminal misconduct, which is conducted by the police, (spe-
cial) prosecutors, courts, and so-called internal review (monitoring) activities.
Therefore, the German system could be described as a highly legalistic system 
that is reluctant to “moralize” ethical conduct within the civil service. Instead, 
the system focuses on the maintenance of the rule of law, the principle of 
merit, and the realization of a public service ethos through a number of (high-
ly specific) civil service principles and norms. Like this, it is less a “Weberian” 
rule-abiding system, but rather a rule of law- and principle-based system.
Consequently, in Germany, the belief is still very strong that government in-
tegrity flows from respecting and applying the rule of law, a public ethos, 
sound administration, classical hierarchical structures, and a specific civil ser-
vice system with life-time tenure, full-time employment, seniority, advanta-
geous pension systems and the existence of career systems. All of these fea-

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tures, it is believed, are necessary in order to reduce as far as possible the 
risk of too much political influence, corruption, misconduct, the exercise of 
private interests, and state capture for private interests. Following this, at a 
minimal level, the German administration is considered to be good and ethi-
cal if it achieves the implementation and enforcement of the existing laws 
and policy goals of the Government of the day. Moreover, ethically good or 
acceptable behavior is defined in terms of rationality, impartiality and the ap-
plication of the merit principle. But not in terms of expected and anticipated, 
concrete behavioral features.
This approach is still widely supported and had its early origins in the skepti-
cism of Immanuel Kant and Niklas Luhman, who either (Kant) did not believe 
in the possibility of defining normative and right/good pure values or (Luh-
man) warned against the moralization of organizational life. Today, influential 
experts like Kuehl (2020) and Armbruster et al. (2021) follow this tradition 
and continue to discuss the ambivalent relationship between organization 
and morality. Together with the still existing Weberian influence and memo-
ries of the fascist period (in which the administration was heavily politicized 
and emotionalized), this makes German decision-makers and civil servants re-
luctant to accept any form of emotional management.
Still, German civil service experts are convinced that specific organizational 
structures, principles and specific civil service features implicitly “produce” 
a certain bureaucratic personality (Merton, 1940), public service ethos, and 
“public service motivation” for civil servants who – in exchange – will be com-
mitted to the public good, neutrality, impartiality and displaying expertise 
(Like this, it can be explained why the German civil service has the most spe-
cific civil service features in Europe in which status, pension systems, sickness 
insurance and working conditions differ most from private sector employees. 
For many Germans, a specific (amoral and functional) civil service is a syno-
nym for institutional integrity. Therefore, German civil servants should follow 
a rational, technical, instrumental, and impersonal understanding of integrity.
4.5 The German Civil Service Ethics System Under Pressure
For a while, Germany is under pressure to adopt the Freedom of Informa-
tion Act, with a particular focus on the scope of exceptions under this act and 
other more recent legislation, the application of these exceptions in practice, 
the system of fees, and the enforcement of the act, whenever necessary. The 
main issue at stake is disclosure requirements of lobbyists, top executives, and 
members of parliament. Mostly, as regards the latter, Germany notes a con-
flict between the duty to disclose interests and (fundamental) privacy rights of 
Members of Parliament. However, Germany also considers that the obligation 
to include requirements for spouses and dependents to declare (financial) in-
terests in disclosure policies constitutes an interference with the constitutional 
rights of those persons obliged to disclose financial information. Germany ar-
gues that it is always necessary to take into account the right to determine the 
use of one’s personal data (Article 2(1) in conjunction with Article 1(1) of the 

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Basic Law) and the right to freely choose one’s occupation (Article 12(1) of the 
Basic Law). “If fundamental rights are affected, interference with these rights 
must serve a legitimate purpose and be suitable for achieving this purpose. 
Such interference must also be necessary to achieve the desired purpose, and 
the intended purpose of the interference must be in reasonable proportion 
to the severity of the interference” (GRECO, 2023). On the other hand, it is 
acknowledged that transparency obligations serve the important purpose of 
preventing corruption among persons with top executive functions. However, 
it is not clear whether detailed disclosure obligations and those of spouses are 
necessary (and proportional) to combat conflicts of interest.
Therefore, Germany is reluctant to require extensive disclosure requirements 
and the sanctioning in practice, in case of non-disclosure. Another challenge 
concerns the management of revolving door policies. For example, GRECO 
notes that Germany has still not introduced an unequivocal obligation to dis-
close various situations of conflicts of interest, as they occur on an ad hoc 
basis. “GRECO also recommended that (i) measures be taken to ensure con-
sistency and transparency of the decisions authorising new occupations of 
state secretaries and directors general following their public service, and (ii) it 
be considered to extend the length of the cooling off period for ministers and 
parliamentary state secretaries, to change the composition of the advisory 
body and to introduce sanctions for failing to comply with decisions of the 
federal government on these matters” (GRECO, 2023).
Also, Germany argues with the existence of value conflicts and, consequently, 
the difficulty in managing revolving door policies effectively. For example, the 
German authorities agree that civil servants (and holders of public service) 
should notify their last employer of any remunerated or other employment 
after leaving their office. This obligation to report employment after leaving 
office represents a necessary and reasonable balance between enforcing ob-
ligations that continue to apply after leaving active public service, but, and on 
the other hand, the right of retired civil servants to freely choose their occu-
pation, according to Article 12(1) of the Basic Law, or the freedom of expres-
sion, arts and sciences according to Article 5(3) of the Basic Law.
Since Germany still has a very traditional civil service system (which is based 
on the principle of life-time tenure), most directors general (and even state 
secretaries) end their careers as civil servants with life tenure by retiring. This 
also explains the (relative) disinterest in Germany for revolving door policies: 
German civil servants rarely move between the public and the private sector. 
Whereas internal mobility within the public service (and even within Minis-
tries, Agencies, etc.) is high, this is not the case as regards mobility between 
sectors (Behncke, 2006, p. 254).
By contrast, high political office in the Federal Government is only held for a 
limited time, and office-holders must often pursue new careers before they 
reach retirement age. Unlike civil servants, they are typically unable to retire 
when they leave office and support themselves with their pension benefits. 
Therefore, rules on the length of cooling-off periods should be applied to dif-

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ferent categories of staff and, if necessary, offer an appropriate balance in 
each individual case between the public interest and the constitutional right 
to freely choose one’s occupation.
However, even if it can be agreed that managing revolving doors is highly 
complex and sensitive, the Federal Government rarely sanctions public offi-
cials in the case of possible violations of cooling-off, or even prohibits offi-
cials from taking up job offers in the private sector (provisions). However, also 
here, managing and enforcing revolving door policies is also considered one 
of the greatest challenges elsewhere in Europe. Together with Germany, all 
countries note that the management of revolving door issues is one of the 
greatest challenges in the field of public ethics. Thus, also here, Germany is 
neither a laggard but also not a forerunner.
4.6 Bureaucratic Germany Against the Emergence of an Ethics 
Bureaucracy
In Germany, awareness is still strong that bureaucratic structures and specific 
civil service features produce the intended integrity results (Huber, 2025). 
This contrasts with research, in which specific public service working condi-
tions and bureaucratic structures did not necessarily produce less corruption 
and a specific public service ethos (Demmke, 2019). Dahlström and Lapuente 
(Dahlström and Lapuente, 2017) examine the existing link between bureau-
cratic structures and corruption. Both authors also conclude that closed bu-
reaucracies are negatively related to the quality of governance. In” The Merit 
of Meritocratization: Politics, Bureaucracy, and the Institutional Deterrents of 
Corruption” Dahlström et al (Dahlström et al., 2012; see also Rauch and Ev-
ans, 2000) concluded that only some factors (most notably the meritocratic 
recruitment of public employees) exert a significant influence on curbing cor-
ruption even when controlling for the impact of most standard political vari-
ables. French experts like Lascoumes (2011) have demonstrated that com-
pliance-based approaches do not work in situations when people are highly 
tolerant of various (and different) forms of wrongdoing. In all of these cases, 
legal obedience will not help (and motivate people to become less tolerant).
Thus, when assessing the German system, we find ourselves in a paradox: On 
the one hand, it is difficult to argue why Germany continues to apply a clas-
sical compliance-based and rather bureaucratic approach to the concept of 
integrity. On the other hand, nobody can deny that the German system works 
well and even outperforms many other reform-minded ethics systems. Even 
more, from a German point of view, many seemingly non-bureaucratic (New 
Public management) countries such as… find themselves in a process of intro-
ducing ever-growing and powerful ethics bureaucracies. Compared to these 
trends, the German approach is rather hesitant and anti-bureaucratic.
In fact, whereas many countries support that the management of integrity 
policies requires sophisticated and complex interventions into personal be-
havior (for example, when monitoring financial- and non-financial interests of 

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employees), from a German point of view, these trends easily turn towards 
a surveillance bureaucracy, easily violate privacy rights and easily turn into 
greedy institutions (Coser, 1974) and moral entrepreneurship that informs 
employees how to behave (Anderson, 2017). In fact, these trends are seen as 
highly problematic: It should never be the role of organisations to interfere 
in personal moral issues. Instead, organisations should be amoral and purely 
functional creatures. Seen from this perspective, transparency is seen as a 
truly ambivalent instrument. On the one hand, transparency and disclosure 
are preferred to classical modes of secrecy and closed forms of bureaucratic 
governance. Overall, transparency is perceived as having positive effects on 
public acceptance and trust. It also enhances policy decisions, which indirectly 
makes people more trusting. Thus, modern transparent instruments like dis-
closure policies are generally perceived to be fairer than secrecy and increase 
the public’s feelings of accountability.
However, it is also claimed that disclosure should be better understood as a 
paradoxical policy and not as a magical device that simply reduces conflicts 
of interest and enhances trust (Sah, 2023). In times of critical governance, 
transparent disclosure policies can be easily abused for personal and political 
interests. Next, effective disclosure depends not only on how people process 
information but also critically on how the disclosure influences the behav-
ior of monitoring officials, underscoring the need for a holistic approach to 
managing conflicts of interest that go beyond mere transparency (Sah, 2023). 
According to our study, monitoring experts in all European countries face a 
quantity challenge (too much data and information), an overload challenge 
(disclosures are too complex, need to monitor different disclosure require-
ments for different categories of staff), and an accumulation challenge (too 
many updating requirements). Especially, the accumulation problem is little 
noticed. Consequently, it is hard to organize and manage the amount of com-
plexity (Ben-Shahar and Schneider, 2014, pp. 8–9).
Thus, the German integrity logic reminds us that, because the management 
of integrity policies is becoming ever more complex and individualized, it is 
time to raise the question of whether or not it would be more effective to 
move back from an individual “bad apple” approach to an institutional integ-
rity approach. While evidence is indeed mounting that the nature of integrity 
policies is strongly moving to accept the importance of (changing) behavioral, 
cognitive, and cultural patterns, the German logic is that the conservative le-
galistic, technical, and impartial approach is not so bad at all.
5 Results and Conclusions
From an international point of view, the German public service ethics system 
is much criticized as being old-fashioned, regulatory, compliance-oriented, 
and exclusively focused on corruption, fraud, criminal enforcement, and the 
enforcement of highly sophisticated civil service rules (Hoekstra, von Mont-
fort and Huberts, 2023). Moreover, the German administrative culture is criti-
cized as not being sufficiently interested in transparency issues, the monitor-

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Christoph Demmke
ing of disclosure and revolving door policies, and the measurement of ethics 
policies, especially as regards conflicts of interest. (GRECO, 2023). Germany 
is also reluctant to introduce a code of conduct for persons with top execu-
tive functions and regarding conflicts of interest and other integrity-related 
matters (e.g. gifts, outside activities, third party contacts, lobbying etc.) and 
that such a code be coupled with a mechanism of control, enforcement and 
sanctions (depending on the breach and its severity) and that is – not only - 
implemented by Parliament (GRECO, 2023)
All of this may be a correct assessment of German ethics policies.
However, from a German point of view, it is important to note that Germany 
performs relatively well as regards most ethics policies and – even better – 
than many other countries such as demonstrated by various good govern-
ance indexes (V-Dem Index, CPI Index, Rule of Law Index, Equality Index and 
Impartiality Index). However, a correct conclusion should be to acknowledge 
that European countries do not know much about themselves and the ef-
fectiveness of their own ethics policies. As regards Germany, trends are to-
wards a more pragmatic reflection about the right regulatory mix, the role of 
self-regulation, moral reasoning and biased judgment, knowledge about the 
effectiveness of deterrence mechanisms and sanctions, the need for better 
integrity policy impact assessments, and the need to overcome the classical 
distinction between compliance-based and value-based systems.
As such, the German ethics system is much more complex than widely as-
sumed. It certainly focuses on a limited and compliance-based logic. It is also 
not very innovative. Still, here, again, Germans would reply: Is innovation in 
the field of ethics a positive trend? (Demmke, 2024). What is innovation? Does 
it really contribute to better outcomes in the field? (Rouet, Raytcheva and 
Come, 2024). From a German point of view, everywhere exists no perfect ethi-
cal organizational recipe, no evidence about a best-practice menu of tools and 
instruments in the field, and no readily established accepted theory of public 
sector innovation in the field of integrity policies (Criado et al., 2023). Our 
study confirms that innovations in the field of ethics policies may themselves 
easily turn into bureaucratized, burdensome, personalized forms of purpose-
driven management. Whereas many innovations are well-intended as a coun-
ter-development to the old bureaucratic and compliance-based approaches, 
they can also be problematic, as personalized forms of management are just 
one step away from personalized monitoring and even individualized social 
credit management practices, or greedy institutional behavior. All of these 
outcomes of innovation raise serious questions about the relationship be-
tween the organization and morality. We are also concerned that, in an era of 
digitalization and artificial intelligence, the positive understanding about (the 
myth of) transparency is slowly disappearing. Instead, transparency policies in 
combination with artificial intelligence raise deep questions about the value 
of privacy, the effectiveness of monitoring, and call into question naïve re-
quests for more and new technologies. Like this, innovation may be as “new” 
as it is “conservative”. Not surprisingly, the EU AI Act has designated the intro-

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duction of AI in national public HR policies as risk area. Will the introduction 
of artificial intelligence contribute to easing administrative burdens, or is the 
concept of innovation nothing but a different word for the creation of a new 
individualized monitoring and control bureaucracy (Demmke, 2024)? These 
critical questions not only challenge the concept of innovation in the field of 
ethics policies. Instead, they only question another central assumption: Are 
ethics policies good policies because they are ethics policies?
Note: The author reports there are no competing interests to declare.

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