Abstract
In this study, we propose considering membership in the Ethics Officer Association (EOA) as a proxy for the firm's commitment to ethical decision making, and we analyze the influence of firm- and CEO-specific characteristics on this commitment. While we observe a positive relationship between membership and firm size, we also document a negative relationship between EOA membership and the executive's time in position and, to a more modest extent, accounting returns. Pursuing this further, we present evidence that firms with past legal issues may seek EOA membership as a signal of their intention to be compliant in the future.