Holding C Suite Leadership Accountable to Ethical Behavior: A Call for Culture, Oversight, and Courage

By Allison Ebner

A CEO and a Chief People Officer Walk into a concert…Hit the jumbotron…And the entire Internet freaks out. For a full 24-hour news cycle. (If you don’t know what I’m talking about, hit up Google. And how do you not know?!) When the details of this began to emerge, my heart sank. She wasn’t just another employee. She was Human Resources. The person in charge of leading and modeling ethical behavior in the organization, along with senior leadership including the CEO that she was with. The fallout was instant and devasting for the individuals involved, their families and the organization (who actually rebounded pretty quickly with a pricey corporate crisis management plan and a very ‘cheeky’ video featuring Chris Martin’s famous ex-wife.)

In today’s business climate, a company’s reputation can be built—or destroyed—by the actions of its CEO and senior leaders. While strong leadership can drive innovation and growth, unchecked power at the top can lead to scandal, employee disengagement, and serious damage to a brand’s credibility. So, how can organizations ensure that their CEOs walk the talk when it comes to ethical behavior? The answer lies in proactive governance, a culture of transparency, and some good old-fashioned checks and balances.

Start with Board Oversight That’s Not Just for Show

If you have a Board of Directors, they are the first line of defense in holding CEOs accountable. But effective oversight goes beyond quarterly meetings and rubber-stamping decisions. Boards need to be active, informed, and independent. That means asking tough questions, demanding real-time data on ethical practices (not just financials), and setting clear expectations around leadership behavior. Having a code of conduct is great—but what’s even better is making sure the board measures the CEO’s actions against it.

One best practice? Create an ethics or governance subcommittee within the board. This group can focus specifically on CEO performance related to culture, compliance, and integrity. It sends a message that ethics is a business priority, not just window dressing.

Tap into External Expertise

Even the best boards and HR teams may not have the time or resources to fully monitor ethical risks. That’s where external advisors come in. Enlisting the help of third-party firms to conduct regular leadership audits, culture assessments, or compliance reviews adds an extra layer of objectivity—and helps avoid blind spots. These outside experts can interview employees confidentially, review communications for red flags, and identify patterns that internal teams may miss.

Whistleblower hotlines, ombudsman services, and anonymous pulse surveys are other external tools that offer insight into whether a CEO is truly modeling the values they preach. Importantly, this feedback loop must be trusted, well-communicated, and acted upon.

Foster a Speak-Up Culture from the Top Down

Holding CEOs accountable also depends on the broader company culture. Are employees empowered to raise concerns through a well-publicized process? Is retaliation taken seriously? If people don’t feel safe speaking up, ethics suffer. CEOs should be evaluated not only on business outcomes but also on how they support psychological safety and two-way communication.

Regular 360-degree feedback—including input from direct reports, peers, and employees at all levels—can be a powerful mechanism. When used consistently, this feedback gives CEOs a more accurate picture of their impact and gives boards data to work with when making decisions about leadership.

Accountability Is a Team Sport

At the end of the day, ethical leadership isn’t a one-person show—it’s the product of strong systems, courageous conversations, and a shared commitment to integrity. Boards, HR leaders, and employees all have a role to play in ensuring CEOs lead with both head and heart. Because when the CEO gets it right, everyone wins. And when they don’t? There should be a process in place that ensures the company—and its people—don’t pay the price.

Our team here at EANE offers many key services to support you with ethics, culture and feedback:

  • HOTLINE service: Our Hotline experts can help guide you through difficult situations
  • Employee Engagement and pulse surveys
  • Workplace investigation services
  • Executive coaching and development
  • Board of Directors consulting services including governance recommendations, CEO performance management, succession planning and more!

Feel free to contact me directly for more information on any of these services. aebner@EANE.org.

Enjoy the rest of your summer!

Allison