to them. ... Corporate officers and directors hold the ultimate power 2° US, DEPT. OF JUSTICE, FCPA Op. RELEASE 08-02 (June 13, 2008), and responsibility for restoring public trust by conducting themselves available at http ://justice.gov/ criminal/fraud/ fcpa/ opinion/2008 /0802. in a manner that is worthy of the trust that is placed in them.” Cynthia pde. Glassman, SEC Implementation of Sarbanes- Oxley: ‘The New Corporate 330) Complaint, SEC v. Rae Sys., Inc., supra note 92; Non-Pros. Agreement, Governance, Remarks at National Economists Club (April 7, 2003), Inve Rae Sys. Inc., supra note 92. available at http://www.sec.gov/news/speech/spch040703cag.htm . 31U,S, DEPT. OF COMMERCE, BusINEss ErHics: A MANUAL FOR 3” Indeed, research has found that “[e|thical culture is the single biggest MANAGING A RESPONSIBLE BUSINESS ENTERPRISE IN EMERGING factor determining the amount of misconduct that will take place ina MarkeET EconomiEs (2004), available at http://www.ita.doc.gov/ business.” ErHics RESOURCE CENTER, 2009 NATIONAL BUSINESS goodgovernance/adobe/bem_manual.pdf. Eruics SuRVEY: ETHICS IN THE RECESSION (2009), at 41. Metrics 32US. DEPT. OF STATE, FIGHTING GLOBAL CORRUPTION: BUSINESS of ethical culture include ethical leadership (tone at the top), supervisor Risk MANAGEMENT (2d ed. 2001), available at http://www.oge.doc. reinforcement of ethical behavior (middle management reinforcement), gov/ pdts/ Fighting Global_Corruption.pdf. and peer commitment (supporting one another in doing the right 333 See HARMONISING ANTI-CORRUPTION COMPLIANCE, supra note thing). ETHICS RESOURCE CENTER, 2011 NATIONAL BUSINESS 302, at 46 (“Anti-corruption compliance is becoming more and more ErHics SURVEY: WORKPLACE ETHICS IN TRANSITION (2012) at 19. harmonised worldwide.”). Strong ethical cultures and strong ethics and compliance programs are 334 QECD Goon PRACTICE GUIDANCE, supra note 309. related, as data show that a well-implemented program helps lead toa 335 APEC ANTI-CORRUPTION CODE,