different ‘faces’, like coercion, manipulation, domination, and sub-
jectification. <fnref n="258" /> Accountors use power to control accountees, in
each of its ‘faces’ and in strong or weak dimensions. Some external
accountors are commissioned by governments (as tax authorities,
inspectors, or courts) and do have strong legitimate authority to
evaluate organizational behaviour, change structures, or replace or-
ganizational leaders. <fnref n="259" /> Strong accountors can, based on law or un-
disputed governmental authority, *force* (coerce) organizations (and
their employees) to account for their actions and to behave as they
deem fit. These accountors use strong, formal accountability mech-
anisms that accountees will find very difficult (more likely: impos-
sible) to neglect. Another (strong or weak) external evaluative force,
with an informal character and using another ‘face’ of power, ma-
nipulation, is the use interest groups or activists make of the media
and popular social networks to influence organizational decision-
making, to place items on the organizational agenda that would
never have appeared otherwise, and to account for organizational
actions that run contrary to their specific demands (like pollution
of the environment.) It threatens the reputations of organizations
and employees, and as such it can manipulate organizations in be-

<footnote>and socio-cultural approaches’, *Management Review*, Vol. 20, No. 4, pp. 413-431; N. Levina, and W.J. Orlikowski (2009). ‘Understanding shifting power relations within and across organizations. A critical genre analysis’, *Academy of Management Journal*, Vol. 52, No. 4, pp. 672-703, and M.M. de Waal (2020). *The Balancing Act of Effective Supervision*. Understanding the Relationship between Internal and External Supervision. University of Groningen, SOM Research School, Groningen. For relational climates and perceptions: Van Bussel (2020), pp. 25-35.</footnote>

<footnote n="258">²⁵⁸ Fleming, and Slicer (2014), 240–245.</footnote>

<footnote n="259">²⁵⁹ R.B. Adams, and D. Ferreira (2012). ‘Regulatory pressure and bank di-
rectors’ incentives to attend board meetings’, *International Review of Fi-
nance*, Vol. 12, No. 2, pp. 227–248.</footnote>
having in a different way. <fnref n="260" /> Internal accountors engage in frequent
contact with other employees and build personal relationships with
them that allow for effective evaluation of everyday decision-mak-
ing, especially because employees are more strongly influenced by
opinions and evaluations of organizational members than by the
opinions of outsiders. <fnref n="261" /> Internal accountors do have more options
available for sanctions or rewards. Employees perceive themselves
to be dependent on them to receive resources, promotions, and
other incentives. These accountors use formal and informal mecha-
nisms of accountability and can use all faces of power in strong and
weak ways. It is for a reason that internal accountors are perceived
by employees to be more powerful than external ones, because they
do have a more serious impact on daily work conditions, on rela-
tional climates, and on perceptions of psychological safety. <fnref n="262" />

The third dimension of organizational accountability is *spatial direction*. Accountability relationships move (ideally) in vertical, horizontal, or diagonal (intermediary) directions. *Vertical accountability* relations are mainly present in accountability relations that are governed by laws and regulations, and, generally, in situations where an accountor wields power over an accountee. In these situations, it requires identification of superiors and subordinates and

<footnote n="260">²⁶⁰ P. David, M.A. Hitt, and J. Gimeno (2001). ‘The influence of activism by institutional investors on R&D’, *Academy of Management Journal*, Vol. 44, No. 1, pp. 144–157, and S. Maguire, C. Hardy, and T.B. Lawrence (2004). ‘Institutional entrepreneurship in emerging fields. HIV/AIDS treatment advocacy in Canada’, *Academy of Management Journal*, Vol. 47, No. 5, pp. 657–680.</footnote>

<footnote n="261">²⁶¹ F. Gino, S. Ayal, and D. Ariely (2009). ‘Contagion and differentiation in unethical behaviour. The effect of one bad apple on the barrel’, *Psychological Science*, Vol. 20, No. 3, pp. 393–398.</footnote>

<footnote n="262">²⁶² De Waal (2020), pp. 30–31.</footnote>
delegation of authority from the former to the latter to create an
obligation to answer for actions. <fnref n="263" /> In *horizontal* accountability,
there are no hierarchical relationships between accountors and ac-
countees and there are, mostly, no formal obligations to ‘be ac-
countable.’ In such relationships, giving account is basically volun-
tary with no designated accountors. It is an obligation that is ethical
or reputational in nature, although there may be formal require-
ments in organizational charters. Organizations giving account of
what they are doing to the ‘general public’ is a horizontal direction
of accountability. Many accountability relationships are not clearly
vertical or horizontal, but have an indirect, intermediary, *diagonal*
direction, ‘accountability in the shadow of hierarchy.’ <fnref n="264" /> Ombuds-
men, auditors, inspectors, and accountants do not have direct hier-
archical relationships with organizations and have only weak pow-
ers to enforce compliance. However, in the end, they report to a
minister, parliament, board, or (specific) shareholders, and from
this derive informal power. <fnref n="265" />

THE MANY MANIFESTATIONS
OF ORGANIZATIONAL ACCOUNTABILITY

‘Many eyes’ and a puzzle.

In daily organizational life, many different manifestations of or-
ganizational accountability (also known as ‘multi-accountability’)
need to be addressed. Many different interests, accountors or their
representatives are watching organizations. Organizations are will-
ing (or obliged) to account for many manifestations of organization-

<footnote n="263">263 Bovens (2007a), pp. 460–462.</footnote>

<footnote n="264">²⁶⁴ Bovens (2007a), p. 460.</footnote>

<footnote n="265">²⁶⁵ Bovens (2007a), p. 460.</footnote>
al accountability. They do need to adhere to different (maybe con-
tradictory) expectations, rules, norms, and standards, set by differ-
ent accountors. Mark Bovens characterized this as the ‘problem of
many eyes’, and I am calling this ‘problem’ the organizational ‘ac-
countability puzzle’.<fnref n="266" /> Managing the perceived or known expecta-
tions of different accountors is an uncertain endeavour, a ‘puzzle’,
in the multidirectional and multi-actor environments organizations
are. It is a ‘puzzle’ to determine ‘who’ is accountable for ‘what’, and
to gather evidence to convince the different accountors of the com-
pliance of the organization to the set standards and expectations.

Thomas Schillemans and Mark Bovens recognize several issues
with multi-accountability, like conflicting expectations, transac-
tion and opportunity costs, emphasis on negativity, blame games,
and symbolic accountability, accountability as a ritual without pos-
itive or negative effects. <fnref n="267" /> They, however, also emphasize an ad-
vantage of such multi-accountability: a multiplicity of demands for
information, with overlap and competition among the sources of
information, will result in more information to be presented to ac-
countors, which has reassuring effects. <fnref n="268" /> They infer hybridity in
accountability relationships and the ‘blurring’ of the boundaries be-
tween the different manifestations of organizational accountability.
The disappearing boundaries between government, market, and so-
ciety, may be a reason for this hybridization. <fnref n="269" /> Anne Marie Goetz

<footnote n="266">266 Bovens (2007a), p. 455.</footnote>

<footnote n="267">²⁶⁷ T. Schillemans, and M. Bovens (2011). ‘The challenge of multiple ac-
countability. Does redundancy lead to overload?’, M.J. Dubnick, and H.G.
Frederickson (eds.), *Accountable Governance. Problems and Promises*, M.E.
Sharpe, Armonk, New York, pp. 2–21, pp. 6–8.</footnote>

<footnote n="268">²⁶⁸ Schillemans, and Bovens (2011), p.19.</footnote>

<footnote n="269">²⁶⁹ A. Benish, and P. Mattei (2020). ‘Accountability and hybridity in wel-
fare governance’, *Public Administration*, Vol. 98, No. 2, pp. 281–290.</footnote>
and Ron Jenkins argue that the source, power, and spatial direction
of organizational accountability are not as straightforward as often
assumed. Ari Salminen and Kirsi Lehto explain that multiple com-
binations of manifestations, vertical and horizontal accountability
relationships, source, and amount of power can exist, based on the
context in which relationships emerge and the different logics, val-
ues, and mechanisms they rely on.<fnref n="270" /> As a result, organizational ac-
countability became mixed in source, power, direction, and mani-
festations, and leads to accountability relations that are more hybrid
in nature. <fnref n="271" /> With this ‘blurring’ of boundaries, strong organiza-
tional governance, strong leadership, strong information govern-
ance and management, and strong ethics management are needed.

As I have emphasized when discussing rules and routines before,
in organizational practice, information systems are used to imple-
ment accountability mechanisms to direct employee behaviour in
prescribed directions. These mechanisms will (mostly) materialize
as formal human resources, finance, and accounting systems (often
integrated in enterprise resource planning systems), but can also be
procedures, rules and regulations to be implemented within busi-
ness processes and the information systems used in those processes.
However, having an organizational policy, rules, procedures, and
aligned information systems does not mean that employees will

<footnote n="270">²⁷⁰ A. Marie Goetz, and R. Jenkins (2001). ‘Hybrid forms of accountability. Citizen engagement in institutions of public-sector oversight in India’, *Public Management Review*, Vol. 3, No. 3, pp. 363–383; A. Salminen, and K. Lehto (2012). ‘Accountability to whom? Exploring the challenge of multiple accountabilities in Finnish public administration’, *Halduskultuur. Administrative Culture*, Vol. 13, No. 2, pp. 147–162.</footnote>

<footnote n="271">²⁷¹ M. Considine (2002). ‘The end of the line? Accountable governance in the age of networks, partnerships, and joined-up services’, *Governance*, Vol. 15, No. 1, pp. 21–40, pp. 21–22.</footnote>
obey, follow and use them as prescribed in their daily work. They
might disregard them in the relational context of decision-making.
In the social dynamics of business, policies might be ignored, misin-
terpreted, or employees might not even be aware of their existence.
In addition, as has been shown before, internal, informal, and sub-
jective mechanisms do have an influence on organizational account-
ability. The formal mechanisms are re-interpreted in the social dy-
namics of work, resulting in variability in subjectively experienced
accountability. Accountability can be ‘felt’ differently among em-
ployees: it is, after all, a perception about demands for answerability
in a given context.<fnref n="272" />

An example. Before 2008, banks and other financials all had for-
mal accountability mechanisms in place. Their managers, bankers,
and traders, however, did not ‘feel’ themselves accountable and an-
swerable for consequences of their myopia to shareholders, govern-
ment institutions, or anyone else. The emphasis on legal compliance
and compliance-based ethics management was proven to be ineffec-
tive. At the same time, integrity-based ethics management, aiming
for high levels of personal and organizational integrity, was ignored.
The existing formal accountability systems could not handle the dif-
ferent interpretations of laws, norms, and standards. They could not
control the trades that were continuously made in decision-making.
Legal compliance did not affect employee behaviour when trading
for individual interests using unethical means, especially when the
costs of control were exponentially higher than the benefits.

Organizational accountability: a framework’s introduction

In the analysis of organizational accountability, often frame-
works are used that distinguish between a number of general mani-

<footnote n="272">²⁷² Hall, Frink, and Buckley (2017), pp. 205–206.</footnote>
festations. These manifestations are then used to explain organiza-
tional accountability, its complexities, its dimensions, its different
'eyes', their effects on organizations, and, sometimes, the informa-
tion needed as evidence to use within the accountability process.
There is no generally accepted typology, rather many proposals, us-
ing a variety of different criteria. Some are based on the *nature* of
the subject: *for what*, for instance political, fiscal, or financial.<fnref n="273" />
Other typologies are based on the different accountors (*to whom*,
like courts, parliament, or peers), and mechanisms (*how*, ministerial
responsibility, judicial or managerial review). <fnref n="274" /> There are many
variations in context and perspective, which results in differences in
the terms (and definitions) used to explain and describe such mani-
festations. Even if terms and definitions are uniform, the connota-
tions are not. They do not allow for generalizations of accountabil-
ity regimes across geographical space and different jurisdictions.

The framework I am presenting here is meant as an overview of
(hybrid) manifestations of organizational accountability that are
bound to West European societal and political contexts, although
they may also be relevant for other spatial and political contexts.
The framework helps to identify the dominant manifestations of
organizational accountability. It is partly based on the division Ma-
shaw made between three (intertwined) domains of organizational
accountability: public, market (or business), and social.

<footnote n="273">²⁷³ For instance, P. Day, and R. Klein (1987). *Accountabilities. Five Public Services*, Tavistock, London, pp. 26–27; and R. Behn (2001). *Rethinking Democratic Accountability*, Brookings Institution, Washington.</footnote>

<footnote n="274">²⁷⁴ For instance: B.S. Romzek, and M. Dubnick (1994). ‘Issues of accountability in flexible personnel systems’, P. Ingraham, and B. Romzek, *New Paradigms for Government. Issues for the Changing Public Service*, Jossey-Bass Inc., San Francisco, pp. 263–294; M. Flinders (2002). *The Politics of Accountability in the Modern State*, Ashgate, Aldershot; Sinclair (1995).</footnote>
I recognize *four* domains: *economic*, *governing*, *social networks*, and *society* (dividing Mashaw's third domain, social, in two separate domains). A short description of these domains:

[1] The *economic* domain is about the use of financial resources and the deliverance of products or services to customers (business-to-business, business-to-consumer, business-to-government, government-to-citizen);

[2] The *governing* domain is about the governing and governance of organizations, be they business or government (or in between);

[3] The *social networks* domain is about the way peers (organizations and employees) and professional associations keep organizations and individual employees accountable for their behaviour; and

[4] the *societal* domain is about all the (unspecified) calls for (business or government) organizations to account for their behaviour to the general public ('society at large') or, at least, to civil interest groups, charities, and associations of clients.

Each of these domains has a distinctive set of goals and values, with different characteristics of authority and legal influence. Authority differs from strong (governing domain), to medium (economic and social network domain), and (relatively) weak (societal domain.) In the governing domain, legal influence is (generally) strong. In the economic and social network domains, law becomes facilitative and leaves freedom of choice. In the societal domain, legal constraints are weak, they facilitate and protect but there are 'law free'-zones of privacy and association. It is 'the arena of norms rather than law.'<fnref n="275" /> Legal constraints can become stronger when 'society' grows concerned about certain phenomena, and pressures governments into action.

<footnote n="275">²⁷⁵ Mashaw (2006), 119–120.</footnote>
Just like Mashaw, I do not include moral and ethical manifestations of organizational accountability in my framework. My reasoning for this is twofold. My first argument is based on Richard Mulgan’s reasoning about the difference between ‘external’ accountability and ‘internal’ (moral) responsibility. Accountability *always* implies *external* scrutiny in a *relationship* between an accountor and an accountee, even if that relationship is informal or the power of the accountor extremely weak.<fnref n="276" /> Moral responsibility is ‘internal’ to an individual, is, as it is called sometimes, ‘accountability-to-self.’<fnref n="277" /> In that case, however, there is *no* external scrutiny and *no* relationship between accountor and accountee, which means it *can-not* be a manifestation of organizational accountability. ‘Accountability-to-self’ is in such a context, a *contradictio in terminis*. An individual may be accountable for *ethical* behaviour, but not on the level of *moral* responsibility. Second, ethical accountability is not a *separate* manifestation but an *integral* part of *all* manifestations of organizational accountability. Accountability is, after all, about ‘being accountable’ to an external audience for decisions and behaviour of employees and organizations, not merely in a legal, political, or bureaucratic sense, but also (and maybe essentially) in an ethical sense. Accountability is an assessment of behaviour, an appraisal of compliant behaviour to laws, regulations, rules, norms, standards, and organizational (or professional) codes of ethics. Not only actions, transactions, and decisions are evaluated, but also if their realization is in accordance with the ethical codes prevalent within an

<footnote n="276">²⁷⁶ For Mulgan’s argument: Mulgan (2003) pp. 15–18. I already mentioned Mulgan’s argument on p. 78 in note 206.</footnote>

<footnote n="277">²⁷⁷ K.A. Ghanem, and P.A. Castelli (2019). ‘Self-accountability in the literature of leadership’, *Journal of Leadership, Accountability, and Ethics*, Vol. 16, No. 5, pp. 40–59. Also: Hall, Frink, and Buckley (2017), pp. 211–212.</footnote>
organization, social network, or profession. That is, after all, the core of ‘being accountable.’<fnref n="278" />

In addition, I do not classify reputational accountability (often mentioned) as a manifestation of organizational accountability but as an integral part of *all* manifestations. As mentioned before, Busu-ioc and Lodge argue that reputational concerns are important in all accountability relationships both for accountors and accountees.<fnref n="279" /> Reputational perceptions influence accountability processes, but there does not exist an accountability relationship that is concerned solely with organizational reputations. Relationships are primarily concerned with other considerations, like politics, legal procedures, environmental operations, or finance. Reputation is a secondary concern in all processes of organizational accountability. Percep-tions of reputation are important for all organizational (and em-ployee) ‘presentations’, external or internal. Reputation is most of-ten managed as a prerequisite for behaviours of employees in all or-

<footnote n="278">²⁷⁸ M. Dubnick (2003). ‘Accountability and ethics. Reconsidering the relationships’, *International Journal of Organization Theory and Behavior*, Vol. 6, No. 3, pp. 405–441, especially pp. 405–408. Based on an experience of more than thirty years as a consultant and external auditor for both (international) government and business organizations, it is obvious for me that accountors try to pay attention to the ethics of behaviour. They mostly concentrate on compliance to laws, regulations, and standards, dependent as they are on information made accessible by the organization itself. About integrity and ethical behaviour, accountors generally do not have much information available because integrity evaluations are often lacking. It is especially in the social networks and societal domains that the integrity of organizational behaviour is questioned. When accountors want to have answers to these public questions about integrity, answers prove to be difficult. Integrity-based ethics management within organizations appears to be in its infancy.</footnote>

<footnote n="279">²⁷⁹ Busuioc, and Lodge (2017), pp. 91–92.</footnote>
ganizational activities. Damaging an organization's reputation is ex-
tremely bad for business. For organizations, thus, reputation is a
consideration that is to be carefully managed, but it is not an ac-
countability manifestation itself in which an organization needs to
account for their reputational actions.

The framework I am presenting here is based on an extensive
analysis of scholarly literature. <fnref n="280" /> The resulting ‘puzzle’ of men-

<footnote n="280">²⁸⁰ Literature used (in chronological order): Day, and Klein (1987); Rom-
zek, and Dubnick (1994); Sinclair (1995); B. Stone (1995). ‘Administrative
accountability in the ‘Westminster’ democracies. Towards a new concep-
tual framework’, *Governance*, Vol. 8, No. 4, pp. 505–526; L. Deleon (1998).
‘Accountability in a ‘reinvented’ government’, *Public Administration*, Vol.
76, No. 3, pp. 539–558; A. Bar Cendón (2000). ‘Accountability and public
administration. Concepts, dimensions, developments’, M. Kelly (ed.),
*Openness and Transparency in Governance. Challenges and Opportunities.
Proceedings of the second NISPAcee Civil Service Forum held in Maastricht,
The Netherlands October 28–29, 1999*, EIPA, Maastricht, pp. 22–61; B.S.
Romzek (2000). ‘Dynamics of public sector accountability in an era of re-
form’, *International Review of Administrative Sciences*, Vol. 66, No. 1, pp.
21–44; Mulgan (2000); Behn (2001); Newell, and Bellour (2002); R.O. Keo-
hane (2003). ‘The concept of accountability in world politics and the use
of force’, *Michigan Journal of International Law*, Vol. 24, No. 4, pp. 1121–
1141; A.M. Meijer, and M.A.P. Bovens (2003). ‘Public accountability in the
information age’, T. van Engers, M.A. Wimmer, and M. Palmarini (eds.),
*E-government. Workshop in conjunction with JURIX 2003*, Rudolf Trauner,
Linz, pp. 16–28; R.E. Goodin (2003). ‘Democratic accountability. The dis-
tinctiveness of the third sector’, *European Journal of Sociology*, Vol. 44, No.
3, pp. 359–396; Dubnick, and Justice (2004); J.C. Burke (2004). ‘The many
faces of accountability’, J.C. Burke (ed.), *Achieving Accountability in Higher
Education. Balancing Public, Academic, and Market Demands*, Jossey-Bass,
San Francisco; R.W. Grant, and R.O. Keohane (2005). ‘Accountability and
abuses of power in world politics’, *American Political Science Review*, Vol.
99, No. 1, pp. 29–43; E. Peruzzotti, and C. Smulovitz (2006). ‘Social Ac-</footnote>
tioned accountability manifestations proved to be a challenge not easy to solve. Dealing with the variety in perspectives, contexts, terms, definitions, and interpretations was not easy, but, in the end, I recognized eleven dominant manifestations of organizational accountability, with (in theory) eleven, but in reality, much more accountors ('eyes.') Nine of these manifestations are both formal and informal, two of them are only informal. They have weak and/or strong accountors, horizontal, vertical, or diagonal directions, and use mechanistic, functional, behavioural, or relational accountabil-

countability. An introduction', E. Peruzzotti, and C. Smulovitz (eds.), *En-forcing the Rule of Law. Social Accountability in the New Latin American Democracies*, University of Pittsburgh Press, Pittsburgh, pp. 3–33; Mashaw (2006); B.G. Peters (2007). 'Performance-based accountability', A. Shah (ed.), *Performance Accountability and Combating Corruption*, The World Bank, Washington, D.C., Chapter 1, pp. 15–32; Bovens (2007ab); G.A. Hodge, and K. Coghill (2007). 'Accountability in the privatized state', *Governance*, Vol. 20, no. 4, pp. 675–702; Willems, and Van Dooren (2011); A. Drake (2012). *Locating Accountability. Conceptual and categorical challenges in the literature*, Policy Report 02, Entwined, Stockholm; Lindberg (2013); E. Akpanuko, and I.E. Asogwa (2013). 'Accountability. A synthesis', *International Journal of Finance and Accounting*, Vol. 2, No. 3, pp. 164–173; A. Aman, T.A. Al-Shbail, and Z. Mohammed (2013). 'Enhancing public organizations accountability through E-Government systems', *International Journal of Conceptions on Management and Social Science*, Vol. 1, No. 1, pp. 15–21; A.R. Keay (2015). *Board Accountability in Corporate Governance*, Routledge, London; Rached (2016); S. Hickey, and S. King (2016). 'Understanding social accountability. Politics, power and building new social contracts', *The Journal of Development Studies*, Vol. 52, No. 8, pp. 1225–1240; Hall, Frink, and Buckley (2017); N.V. Christie (2018). A comprehensive accountability framework for public administrators', *Public Integrity*, Vol. 20, No. 1, pp. 80–92; S. Overman, and T. Schillemans (2021). 'Toward a public administration theory of felt accountability', *Public Administration Review*, https://doi.org/10.1111/puar.13417.
ity mechanisms. Organizations are confronted, more or less, di-
rectly or indirectly, with all these manifestations, and with accoun-
tors for each of them.

For all formal dimensions of these manifestations, enterprise in-
formation management is needed as accountors have a need for ‘ev-
idence.’ For the societal domain, informal by nature, information
may be of importance to deny media claims or allegations of interest
groups, especially when such claims turn into a legal battle. ‘Integ-
rity’, however, is not something that can be easily derived from
such ‘evidence.’ Normally, accountors ask more than ‘evidence’;
they want to be assured of the integrity of behaviour. For that rea-
son, codes of ethics are necessary, as well as evidence that employee
behaviour is continuously evaluated against it. Rewards and punish-
ments for employees for behaviour according to or against the code
of ethics will go a long way to assure accountors of the organiza-
tions’ efforts to assure employee integrity.

Organizational accountability: a framework

As mentioned before, I recognize four domains that group
eleven manifestations of organizational accountability. These do-
mains are not meant as a typology of accountability regimes belong-
ing to ‘the market’ or ‘the government’ (as Mashaw did) but as areas
that influence organizational accountability. All organizations are
influenced by accountability manifestations that are economic, gov-
erning, social networks, or societal in nature. The manifestations
belonging to these domains can be seen as ideal types applicable to
all organizations, be they government or business organizations (or
in between.) Organizations are, after all, becoming hybrid entities
that integrate elements, value systems, and action logics of various
sectors of society because they have multiple external relations and
operate in the border area between different worlds (like government and market).<fnref n="281" />

In Figure 1, I present an overview of my framework of manifestations of organizational accountability. For each domain, I will introduce and describe the different manifestations, addressing the specific traits and problem areas. For each manifestation several characteristics are mentioned: its direction, source, power, who, to whom, about what, through what procedures, by what standards, which consequences, if enterprise information management is necessary or not, and which type of ethics management is dominant.

<table><caption>Figure 1. Manifestations of organizational accountability</caption><thead><tr><th colspan="2">Manifestations of organizational accountability</th></tr></thead><tbody><tr><td>Economic Domain</td><td>1. Financial Resources accountability<br>2. Product-Services accountability</td></tr><tr><td>Governing Domain</td><td>3. Administrative accountability<br>4. Fiscal accountability<br>5. Legal accountability<br>6. Managerial accountability<br>7. Board (or Directors) accountability<br>8. Political accountability</td></tr><tr><td>Social Networks Domain</td><td>9. Peer accountability<br>10. Professional accountability</td></tr><tr><td>Societal Domain</td><td>11. Social and Environmental Accountability</td></tr></tbody></table>

<footnote n="281">²⁸¹ M. Ciesielska (2010). *Hybrid Organisations. A Study of the Open Source-Business Setting*. PhD series No. 32.2010, CBS, Copenhagen, p. 25.</footnote>
## The economic domain

The *economic* domain is about the use of financial resources and the deliverance of products and/or services to customers or citizens. It groups two manifestations: [1] financial resources accountability, and [2] product-service accountability.

<table><caption>Figure 2. Financial Resources accountability</caption><thead><tr><th colspan="2">Economic Domain</th></tr><tr><th colspan="2">1. Financial Resources accountability</th></tr></thead><tbody><tr><td>Direction:</td><td>Vertical</td></tr><tr><td>Source:</td><td>Formal</td></tr><tr><td>Power:</td><td>Strong</td></tr><tr><td>Who</td><td>Organizations, (board of) directors</td></tr><tr><td>To whom:</td><td>External: owners, financial institutions, government (institutions), tax authorities.<br>Internal: managers and (board of) directors</td></tr><tr><td>About:</td><td>Management of financial resources</td></tr><tr><td>Procedures:</td><td>Formal, defined by laws, regulations, and accounting standards</td></tr><tr><td>Standards:</td><td>Laws, regulations, and accounting standards</td></tr><tr><td>Consequences:</td><td>Penalties, dependent on jurisdiction, loss of trust of financial and fiscal institutions</td></tr><tr><td>EIM<br>Ethics Management</td><td>Necessary<br>Compliance and integrity</td></tr></tbody></table>

This first manifestation is, according to (for instance) Newell and Bellour, originally concerned only with keeping accurate accounts but is expanding to the management of all financial resources.<fnref n="282" /> It refers to the financial transactions and compliance with legal, regulatory, contractual, and procedural requirements for the acquisition and utilization of financial resources in appropriate qual-

<footnote n="282">²⁸² Newell, and Bellour (2002), p. 10.</footnote>
ity and quantity at the lowest cost. Organizations obtain the funds
to finance their investments, capital, and/or activities from financial
institutions, capital markets, shareholders, or governments (in the
case of government organizations, or as a grant for research and de-
velopment). Financial integrity is of the utmost importance. Funs-
ders want to be sure that organizations manage their finances re-
sponsibly. An organization wants its financial image to not only be
technically accurate (although that is extremely important) but also
that it is handled effectively and efficiently, without unethical be-
haviour (like fraud). For that reason, financial control systems are
quite common in most organizations.

Financial resources accountability encompasses two business
processes: for adequate tax compliance (closely related with fiscal
accountability), and for tracking and reporting on allocation, dis-
bursement, and utilization of financial resources. For both these
business processes the tools of auditing, budgeting, and accounting
are used. A focus on (ethical) behaviour of employees and on finan-
cial procedure is essential.<fnref n="283" /> Organizations are accountable for re-
sponsible and productive use of money, verification of legality, pro-
priety, and regularity of financial actions and transactions, paying
government taxes as is obligated by tax authorities, and for making
sure that the use of financial resources achieves value for money.<fnref n="284" />
In short, accountors check capital, liquidity, revenues, costs and
risks, and the way organizations handle these in daily practice.

<footnote n="283">²⁸³ Y. Zhang, and V. Mittal, ‘Decision difficulty. Effects of procedural and outcome accountability’, *Journal of Consumer Research*, Vol. 32, No. 3, pp. 465–472, p. 471.</footnote>

<footnote n="284">²⁸⁴ A. Rabrenović (2007). *Financial Accountability as a Condition for EU Membership*, Ph.D. thesis University of Glasgow, Glasgow, p. 27. Online source, retrieved on November 19, 2021, from: http://theses.gla.ac.uk/2265/1/2007rabrenovicphd.pdf.</footnote>
Financial reporting summarizes the information upon which de-
cisions are made and indicates whether available resources were ob-
tained and used in accordance with existing regulations, contractual
obligations, assigned budgets, and expectations of accountors. Re-
ports provide detailed information about the financial condition of
the organization, the yearly changes therein, and the organization's
performance in terms of service costs, efficiency, and accomplish-
ments, constraining individuals from engaging in corruption. They
are needed for informing their funders about the financial health of
the organization.

An organization's compliance to financial and fiscal laws, regu-
lations, and norms is a subject of reporting to the 'public', and, just
like the reports to their funders, these reports are based on financial
and fiscal audits. There is scrutiny for financial and tax transparency
in society, and organizations want, for their reputations sake, im-
press the public that they work according to laws and regulations
and that there can be no doubt about their financial integrity.<fnref n="285" />

Integrity is problematic. A report from Cristina Neesham and
Mohammad Azim, both from Swinburne University of Technol-
ogy in Australia, offers a glimpse of the ethical problems accounting
professionals face in their accounting control in organizations. Pro-
fessionals encounter misleading reporting, fraud, tax evasion, lack
of transparency in financial decisions, bribery, misuse of funds, and
insider trading. External accountants are extremely worried about
being pressured into unethical actions by their customers (or, just

<footnote n="285">²⁸⁵ Respectively: W. Ge, Z. Li, Q. Liu, and S. McVay (2021). ‘Internal control over financial reporting and resource extraction. Evidence from China’, *Contemporary Accounting Research*, Vol. 38, No. 2, pp. 1274–1309 and C.H. Chen (2011). ‘The major components of corporate social responsibility’, *Journal of Global Responsibility*, Vol. 2, No. 1, pp. 85–99.</footnote>
as bad, their own board).<sup>286</sup> Besides compliance-based ethics management, integrity-based ethics management is, thus, a necessity.

<table><caption>Figure 3. Product-Services accountability</caption><thead><tr><th colspan="2">Economic Domain</th></tr><tr><th colspan="2">2. Product-Services accountability</th></tr></thead><tbody><tr><td><em>Direction:</em></td><td>Vertical, horizontal, and diagonal</td></tr><tr><td><em>Source:</em></td><td>Formal and informal</td></tr><tr><td><em>Power:</em></td><td>Strong</td></tr><tr><td><em>Who</em></td><td>Organizations, (board of) directors</td></tr><tr><td><em>To whom:</em></td><td><em>External</em>: customers (business-to-consumers), citizens (government-to-citizens), business organizations (government-to-business, vice versa) and customers (business-to-business)</td></tr><tr><td><em>About:</em></td><td>Quality of products and service delivery</td></tr><tr><td><em>Procedures:</em></td><td>Formal and informal</td></tr><tr><td><em>Standards:</em></td><td>Debatable, but satisfaction of customers/citizens is prominent</td></tr><tr><td><em>Consequences:</em></td><td>Loss of trust of customers and citizens</td></tr><tr><td><em>EIM</em></td><td>Recommended</td></tr><tr><td><em>Ethics Management</em></td><td>Compliance and integrity</td></tr></tbody></table>

The second manifestation of organizational accountability within the economic domain is product and/or services accountability. This manifestation relates, in theory, to the ‘system of supply and demand, in which the free choices of the public are given free reign and considerations of efficiency also play a role.’<sup>287</sup> In a ‘normal’

<footnote n="286"><sup>286</sup> C. Neesham, and M.I. Azim (2017). *Building Ethical Capability for Accounting Professionals. A Needs Analysis Study*, Swinburne University of Technology, Hawthorn, Melbourne.</footnote>

<footnote n="287"><sup>287</sup> J.L.H. Bardoel, and L. D’Haenens (2004). ‘Media responsibility and accountability. New conceptualizations and practices’, *Communications*, Vol. 29, pp. 5–25, p. 9.</footnote>
market, control is based upon the idea that the behaviour of buyers and sellers determines not only price but also an acceptable ratio between quality and price. Economic behaviour is based on competition between different sellers that is controlled by loyalty as a reward for compliant behaviour and exit as punishment for deviant behaviour. That means that in a market the sellers are accountees, accountable to the buyers as accountors. Customers (buyers) are free to buy a product or a service from a seller and can change when product quality or behaviour of the seller are not to his or her liking. Besides the possibility to leave, there are formal possibilities to complain in complaints procedures of the seller and of customer associations. This last one, can be 'bad' for the reputation of the seller and, in the end, for the economic standing and profit of that business organization. <fnref n="288" />

Although this mechanism of control and accountability is dominant in business-to-consumer, business-to-government, and business-to-business, a fully 'free' market does not exist. The market is controlled, be it by strong actors (like insurance companies, for risks, and credit rating agencies, for financial behaviour) or by the government which tries to 'steer' market forces. Instead of owning and substantially funding organizations of service delivery (like higher education, healthcare, or waste management), governments can shape markets by purchasing or subsidizing the services they want. This approach allows governments to shape responses to market mechanisms to achieve greater efficiency in the use of public resources. <fnref n="289" /> Governments create (formalized) 'quasi-markets',

<footnote n="288">²⁸⁸ C. Scott (2006). 'Spontaneous accountability', M.W. Dowdle (ed.), *Public Accountability. Designs, Dilemmas and Experiences*, Cambridge University Press, Cambridge, pp. 174-191, pp. 178-180. Also: Burke (2004), p. 17.</footnote>

<footnote n="289">²⁸⁹ Burke (2004), p. 17.</footnote>
where business principles and contracts are used between business
organizations and government organizations (as customers). Gov-
ernments, however, do not offer freedom of choice to their ‘ cus-
tomers’ (citizens and business organizations), obliging them to ac-
cept ‘services’ from the contracted services the government pur-
chased, mostly excluding competing service contractors. The ques-
tion *who* is accountable to *whom, for what, and how* is difficult to
answer in such (diagonal) situations.<fnref n="290" /> In addition, it is impossible
for citizens and business organizations to ‘buy’ government prod-
ucts and services from another government agency than their own
(licenses, for instance). Accountability of ‘quasi-markets’ is, thus,
not based on market principles. <fnref n="291" />

Another problem arises when products, like algorithms, are in-
tellectual property of business organizations and information about
the way a product works in (decision) processes the using organiza-

<footnote n="290">²⁹⁰ Ç.D. Çolak (2019). ‘Why the New Public Management is obsolete. An analysis in the context of the Post–New Public Management trends’, *Cro-atian and Comparative Public Administration*, Vol. 19, No. 4, pp. 517–536. Online source, retrieved on November 19, 2021, from: https://hrcak.srce.hr/index.php?show=clanak&id_clanak_jezik=335808&lang=en. Willems, and Van Dooren (2011), pp. 517–518.</footnote>

<footnote n="291">²⁹¹ W. Funnell (2001). *Government by Fiat. Retreat from Responsibility*, UNSW Press, Sydney, Chapter 1, pp. 1–25, especially pp. 1–2. Funnell is critical of the results of new public management and neo-liberal ideologies for society at large. According to him, it resulted in the transformation of citizens into clients and customers, into growing inequality and greater privilege for interest groups, and in the alienation of citizens from elected governments. Funnell argues that reduced government presence facilitated government retreat from responsibility. ‘Not only have governments been less willing to accept longstanding obligations for their citizens, they have become even more secretive about that which remains for governments.’</footnote>
tion is accountable for, is refused. Finding another seller may work but does not solve the problem. Product-services accountability seems straightforward, but it shows accountability problems that are not easily solved. It only works as intended in completely 'free' markets, and even there the relationship between business organization and consumer is not as simple as is assumed, largely because of the immense inequality between both parties in the relationship.

## The governing domain

The governing domain is about the governing and governance of organizations, business as well as government organizations (or in between). It groups six manifestations of organizational accountability: [3] Administrative accountability, [4] Fiscal accountability, [5] Legal accountability, [6] Managerial accountability, [7] Board (or directors) accountability, and [8] Political accountability.

<table><caption>Figure 4. Administrative accountability</caption><thead><tr><th colspan="2">Governing Domain</th></tr><tr><th colspan="2">3. Administrative accountability</th></tr></thead><tbody><tr><td>Direction:</td><td>Vertical</td></tr><tr><td>Source:</td><td>Formal</td></tr><tr><td>Power:</td><td>(Mostly) strong</td></tr><tr><td>Who</td><td>Employees (internal), Boards (Directors) (external)</td></tr><tr><td>To whom:</td><td>Internal: managers and (board of) directors<br>External: supervising and control institutions</td></tr><tr><td>About:</td><td>Following rules, regulations, and procedures for operations</td></tr><tr><td>Procedures:</td><td>Formal, dependent on jurisdiction and organization</td></tr><tr><td>Standards:</td><td>Defined in laws, regulations, standards, and procedures</td></tr><tr><td>Consequences:</td><td>Promotion, gratuities, demotion, dismissal</td></tr><tr><td>EIM</td><td>Necessary</td></tr><tr><td>Ethics Management</td><td>Compliance</td></tr></tbody></table>
Within the vertical structures of this manifestation organization-
al actions, transactions, roles, and functions can be examined in de-
tail. Accountability processes start at the top, with the highest offi-
cial, and take place along the ‘chain of command’. It is the delega-
tion of authority from superior to subordinate and corresponding
accountability from subordinate to superior. It is about accounta-
bility for the procedures used to reach a decision, a product, or a
service, regardless of the result of the procedure. It affects most of
the other manifestations of organizational accountability. Managers
have the right to request information regarding the operations from
lower levels, but not from higher ups. They can directly decide
about juniors’ careers, promotion, and conditions of work.<fnref n="292" />

Administrative accountability is about the workings of an or-
ganizational system as a whole and its compliance to rules and reg-
ulations. Donald Kettl stated that administrative accountability is
channeled by the rule of law but that in daily practice the workings
of the system have been drifting beyond its bounds. As a result, the
standards for administrative accountability and its regulations be-
came fuzzier and arbitrary. <fnref n="293" /> Kettl distinguishes between three
types of administrative accountability with different relationships
to the ‘rule of law’ and with different standards for accountability:
[1] *Direct* administrative accountability occurs through authority–
driven hierarchical and vertical structures in which law and regula-
tions can be enforced; [2] *Mediated* administrative accountability oc-
curs through contracts, where there is a substantial body of law that
is more difficult to enforce; and [3] *Privatized* administrative ac-
countability occurs through business organizations providing ser-

<footnote n="292">²⁹² Lindberg (2013), p. 12.</footnote>

<footnote n="293">²⁹³ D.F. Kettle (2009). ‘Administrative accountability and the rule of law’, *Political Science and Politics*, Vol. 42, No. 1, pp. 11–17, p. 11.</footnote>
vices that contain privatized government activities. <fnref n="294" /> The administrative accountability types result in a cascade of information asymmetries. Direct administrative accountability is dominated by law, mediated accountability has a clear rule of contract law but also moral hazards that make that law hard to enforce, and privatized accountability has ‘little law’, challenging problems in defining *who* is accountable, and needs to use norms and standards other than law to regulate accountability processes. <fnref n="295" /> The application of norms and standards is voluntary although compliance could become an issue for their customers. Applications and third-party memoranda about compliance could also be used as an assurance in the accountability relationship with administrative accountors.

Enterprise information management is a core functionality for this manifestation, in each of its types. To be accountable, administrative scrutiny of rules and regulation is a necessary ‘evil’ for each of these types. Management of information as evidence of actions and transactions is important in an administrative environment, especially when there is ‘little law.’ In each type, determining who is accountable is difficult, because organizations *are* complex systems. When there is ‘little’ rule of law, it is even more difficult to determine and regulate an accountability relationship. In each type, organizations try to define in (more or less) detail the tasks, roles, and responsibilities of all participants in a business process. The idea is that blameworthy behaviour might be found out, and precisely defining business processes should avoid that behaviour. This, however, often develops into strict rule structures that lead, as shown before, <fnref n="296" /> to the misbehaviour they intend to prevent, to routines

<footnote n="294">²⁹⁴ Kettle (2009), p. 14–16.</footnote>

<footnote n="295">²⁹⁵ Kettle (2009), p. 14.</footnote>

<footnote n="296">²⁹⁶ Van Bussel (2020), pp. 85-91.</footnote>
<table><caption>Figure 5. Fiscal accountability</caption><thead><tr><th colspan="2">Governing Domain</th></tr><tr><th colspan="2">4. Fiscal accountability</th></tr></thead><tbody><tr><td>Direction:</td><td>Vertical</td></tr><tr><td>Source:</td><td>Formal</td></tr><tr><td>Power:</td><td>Strong</td></tr><tr><td>Who</td><td>Organizations, Board (of directors)</td></tr><tr><td>To whom:</td><td>External: Government budget agencies and tax authorities</td></tr><tr><td>About:</td><td>Paying taxes, collecting taxes (value added tax)</td></tr><tr><td>Procedures:</td><td>Formal</td></tr><tr><td>Standards:</td><td>Defined in laws, regulations, and fiscal standards</td></tr><tr><td>Consequences:</td><td>Penalties, dependent on jurisdiction, loss of trust of financial, fiscal, and tax authorities</td></tr><tr><td>EIM</td><td>Necessary</td></tr><tr><td>Ethics Management</td><td>Compliance</td></tr></tbody></table>

Fiscal accountability, strongly related to the financial and administrative manifestations, is seen as ‘one of the main prerequisites for better macro-economic and fiscal stability, better credit ratings and better fiscal discipline (lower public debt and deficits), reduced levels of corruption and a determinant for higher rates of economic growth.’ <fnref n="300" /> It is a key element in the management of government finances determining fiscal risks, financial decision-making, and improving fiscal policies. It is being accountable for a balance between spending and revenues (taxes), the reasoning behind decisions, and

<footnote n="300">³⁰⁰ Following: B. Trenovski (2017). *Fiscal Transparency, Accountability and Institutional Performances as a Foundation of Inclusive and Sustainable Growth in Macedonia*. Public Paper World Bank, Washington, p. 1. Online source, retrieved November 19, 2021, from: https://pubdocs.worldbank.org/en/278551516728264974/Borce-Trenovski-1.pdf.</footnote>
management of budgets. Government organizations can only exist when attributed a budget to use for operations and service delivery to ‘customers.’ They do have a strong responsibility and accountability for use and management of these budgets, obliging them to report regularly. <fnref n="301" /> There are strong supervising mechanisms in place that have influence on financial and administrative procedures. Because budgets are based on taxes, the public at large has an interest in the efficiency and effectivity of government operations.

For business organizations, fiscal accountability has a marked effect. Governments (and the media, civil society, and the public at large) want assurances that business organizations are contributing to the societies in which they operate. Governments recognise that tax systems could stimulate the competitiveness of their economies and the ability to attract investments. It is not uncommon to reach agreements with business organizations that allow them tax expenditures (exemptions, credits, deductions, preferential rates, and abatements.) <fnref n="302" /> These expenditures, although politically a useful fiscal instrument, do have unintended consequences in an economy in which international tax competition and ‘tax-avoidance’ are common. It puts downward pressure on tax revenues. Multinationals shift approximately forty-two per cent of their profits to low-tax countries to avoid taxes. In Ireland, for instance, Apple has paid in

<footnote n="301">³⁰¹ M. Schoch, C. den Broeder (2013). ‘Linking information on policy ef- fectiveness and efficiency to budget decisions in the Netherlands’, *OECD Journal on Budgeting*, Vol. 12, No. 3, pp. 1–22.</footnote>

<footnote n="302">³⁰² J. Levitis, N. Johnson, and J. Koulish (2009). *Promoting State Budget Accountability through Tax Expenditure Reporting*, Center on Budget and Policy Priorities, Washington, p. 5. Also: Tax expenditures are ‘a special provision of the tax system that reduces tax liability for a certain subset of taxpayers.’ R. Altshuler, and R. Dietz (2011). ‘Reconsidering tax expenditure estimation’, *National Tax Journal*, Vol. 64, No. 2, pp. 459–489, p. 459.</footnote>
some years a minuscule annual tax rate as low as 0.005 per cent. 303 Such practices result in severe criticism and led to a proposal for a minimum global tax of fifteen per cent for business organizations. At the same time, these organizations also collect taxes as unpaid tax collectors, value added tax, for instance, and a range of labour taxes. The impact that taxes (and the tax systems used) have on business organizations is important both in terms of direct cost, and of compliance costs. Tax authorities, however, do have strong power to force compliance, and although many business organizations try to limit their taxes to the bare minimum, it is impossible for them to completely escape from paying taxes.

<table><caption>Figure 6. Legal accountability</caption><thead><tr><th colspan="2">Governing Domain</th></tr><tr><th colspan="2">5. Legal accountability</th></tr></thead><tbody><tr><td>Direction:</td><td>Vertical</td></tr><tr><td>Source:</td><td>Formal</td></tr><tr><td>Power:</td><td>Strong</td></tr><tr><td>Who</td><td>Organizations, Board (of directors), employees</td></tr><tr><td>To whom:</td><td>External: Courts and tribunals</td></tr><tr><td>About:</td><td>Holding officials/employees/organizations legally responsible</td></tr><tr><td>Procedures:</td><td>Formal</td></tr><tr><td>Standards:</td><td>Laws and regulations</td></tr><tr><td>Consequences:</td><td>Legal sanctions</td></tr><tr><td>EIM</td><td>Necessary</td></tr><tr><td>Ethics Management</td><td>Compliance and integrity</td></tr></tbody></table>

<footnote n="303">303 J.E. Stiglitz, T.N. Tucker, G. Zucman (2020). ‘The starving state. Why capitalism’s salvation depends on taxation’, *Foreign Affairs*, Vol. 99, No. 1, 30–38. Online source, retrieved on November 19, 2021, from: https://www.foreignaffairs.com/articles/united-states/2019-12-10/starving-state?</footnote>
The legal manifestation of organizational accountability is of in-
creasing organizational importance as a result of [1] an evolving for-
malization of social relations, more trust in courts, and the prevalence of law, <fnref n="304" /> and [2] the problematic adjustment of the existing accountability mechanisms to a complex and fragmented society.
Jeff King argues that six essential attributes characterize legal ac-
countability: [1] an individual right of petition; [2] a functionally independent adjudicator; [3] interpretation and application of publicly affirmed legal standards; [4] decisions that are interpretations of applicable standards, are responsive to the principal submissions, and are ordinarily published; [5] a declarative or coercive remedy; which is [6] final (subject to appeal or reversal by due process of law.) <fnref n="305" /> Legal accountability needs trusted information as evidence.
The degree of control is high and detailed. New doctrines, procedural mechanisms, and forms of relief enable law to take part in the regulation of state and organizational power.

Legal accountability mechanisms do have limitations. Their ac-
cess is problematic, their scope limited, and they promise more than
can be delivered. <fnref n="306" /> They, however, enable law to exert control over
government and organizational power by providing ‘tin openers’ to

<footnote n="304">³⁰⁴ Harlow (2002). Also: D.M. Katz, C. Coupette, J. Beckedorf, and D. Hartung (2020). ‘Complex societies and the growth of the law’, *Scientific Reports*, Vol. 10, art. 18737. Online source, retrieved on November 19, 2021, from: https://doi.org/10.1038/s41598-020-73623-x.</footnote>

<footnote n="305">³⁰⁵ J.A. King (2013). ‘The instrumental value of legal accountability’, N. Bamforth, and P. Leyland (eds.), *Accountability in the Contemporary Constitution*, Oxford University Press, Chapter 6, pp. 124–152, p. 127.</footnote>

<footnote n="306">³⁰⁶ As is the general argument of: C. Harlow, and R. Rawlings (2009a). ‘Ju-
dicial review and administration. A tangled web’, C. Harlow, and R. Rawl-
ings, *Law and Administration*, Cambridge University Press, Cambridge,
third edition, Chapter 16, pp. 711–748, pp. 747–748.</footnote>
courts for exposing organizations to judicial procedures. 307 It is re-
active, based on evidence, and conducted through investigations by
external monitoring agencies. Trusted information is important as
evidence.

Although legal reviews are ‘supported by the weight of law, and
the underlying value is the rule of law’, legal accountability is man-
ifest in arenas far beyond courts of law. 308 This legal manifestation
is used to subject organizations to an extensive range of controls,
which allow for legal evaluations and sanctions. Legal accountabil-
ity is the most unambiguous of all manifestations of organizational
accountability, as it is based on detailed legal standards, prescribed
by civil, penal, or administrative statutes. 309 These standards are to
be followed and compliance may be enforced by legal accountors.
Governments and business organizations use the courts also when
citizens, business organizations, or consumers are suspected of devi-
ant or unlawful behaviour, like fraud.

Multinational organizations wield considerable political influ-
ence and possess more economic power than some governments. 310
Many have developed close business and political relationships with
those in power. Through privatization and sub-contracting, busi-
ness organizations exercise functions that once were reserved for

<footnote n="307">307 C. Harlow, and R. Rawlings (2009b), ‘Transforming judicial review’, C. Harlow, and R. Rawlings, *Law and Administration*, Cambridge University Press, Cambridge, third edition, Chapter 3, pp. 95–139, p. 126.</footnote>

<footnote n="308">308 Romzek (2000), p. 25.</footnote>

<footnote n="309">³⁰⁹ Bovens (2007a), p. 456.</footnote>

<footnote n="310">310 M. Babic, J. Fichtner, and E.M. Heemskerk (2017). ‘States versus corporations. Rethinking the power of business in international politics’, *The International Spectator*, Vol. 52, No. 4, pp. 20–43. Online source, retrieved on November 19, 2021 from: https://www.tandfonline.com/doi/full/10.1080/03932729.2017.1389151.</footnote>
governments. Interest groups have increasingly turned to the courts to constrain power of business organizations. This has led to a search for how national and international law can be used to hold non-government actors accountable when they do harm (in human rights, for instance.) <fnref n="311" />

<table><caption>Figure 7. Managerial accountability</caption><thead><tr><th colspan="2">Governing Domain</th></tr><tr><th colspan="2">6. Managerial accountability</th></tr></thead><tbody><tr><td><em>Direction:</em></td><td>Vertical</td></tr><tr><td><em>Source:</em></td><td>Formal</td></tr><tr><td><em>Power:</em></td><td>Strong</td></tr><tr><td><em>Who</em></td><td>Managers</td></tr><tr><td><em>To whom:</em></td><td><em>Internal:</em> Senior managers and/or (Board of) Directors</td></tr><tr><td><em>About:</em></td><td>Results</td></tr><tr><td><em>Procedures:</em></td><td>Formal</td></tr><tr><td><em>Standards:</em></td><td>Internal indicators for management roles and performance criteria</td></tr><tr><td><em>Consequences:</em></td><td>Internal sanctions and/or gratuities</td></tr><tr><td><em>EIM</em></td><td>Recommended</td></tr><tr><td><em>Ethics Management</em></td><td>Compliance and integrity</td></tr></tbody></table>

This manifestation of accountability refers to the answerability of managers for the results of their domain of work to the managers senior to them, or to the (board of) directors. It implies accountability for all aspects of their management level, from planning to reporting and from delegation to control. Managerial accountability

<footnote n="311">³¹¹ International Commission of Jurists (2009). *Corporate Complicity & Legal Accountability*. Report of the International Commission of Jurists Expert Legal Panel on Corporate Complicity in International Crimes, ICJ, Geneva, pp. 1–2.</footnote>
means both conformity to rules and procedures (compliance) and
focus on results (performance), all evidence-based, so information
management is important. <fnref n="312" /> Evaluation is also about behaviour of
managers in reaching those results. It is related with political and
board accountability, because without managerial accountability
both of those manifestations would be difficult to realize.

Sometimes this manifestation is regarded as identical with the
administrative manifestation, because they arise both by virtue of
an employee's position in power structure of an organization. <fnref n="313" /> It
is, however, more about the professional behaviour of managers,
monitoring inputs and outputs (or outcomes) according to agreed
performance criteria. It is about making sure that money has been
spent as agreed, processes and courses of action are efficiently car-
ried out, and programmes have achieved their intended results.
Managerial accountability is interested in the quality of the product
or service, and not in the quality of the procedure, as is the case for
administrative accountability. <fnref n="314" /> The focus of managerial account-
ability is on doing the ‘right’ things efficiently and effectively.

Managers are held accountable for results by assigning them re-
sponsibility, authority for decision-making, and the autonomy and
resources necessary to achieve these results. <fnref n="315" /> According to War-
wick Funnell, flexibility in decision-making, risk-taking, and eval-

<footnote n="312">³¹² K. Klaas, L. Marcinkowski, and M. Lazarević (2018). *Managerial Ac-countability in the Western Balkans. A Comparative Analysis of the Barriers and Opportunities faced by Senior Managers in Delivering Policy Objectives*. SIGMA Papers, No. 58, Paris. Online source, retrieved on November 19, 2021, from: https://read.oecd-ilibrary.org/governance/managerial-ac-countability-in-the-western-balkans_88be2112-en#page1.</footnote>

<footnote n="313">³¹³ Sinclair (1995), p. 227.</footnote>

<footnote n="314">³¹⁴ Newell, and Bellour (2002), p. 9; Sinclair (1995), p. 227.</footnote>

<footnote n="315">³¹⁵ Klaas, Marcinkowski, and Lazarević (2018), p. 11.</footnote>
uating performance by measurable results are the primary consider-
ations in managerial accountability. He argues that, overall, ac-
countability is weakened because of the emphasis on performance
within its managerial manifestation. Services (and the information
about them) are more about technical efficiency and performance
than about effective delivery. It means more control by managers
rather than greater scrutiny. <fnref n="316" /> Jane Broadbent and Richard Laugh-
lin summarize that the managerial manifestation is about how man-
agers operate and control day-to-day operations and how they are
accountable for processes, performance, and programmes. <fnref n="317" />

This manifestation of organizational accountability is an integ-
rity challenge, too. As research shows, scrutiny for managerial be-
haviour is needed. Not only has the base rate for managerial incom-
petence been rated to average above fifty per cent, it is also estimated
that the base rate for low integrity managers is in the ten to twenty
per cent range. <fnref n="318" /> This implies that every organization employs sev-
eral managers that harm their organization and its employees. Pro-
per oversight, and periodic assessments are needed to prevent these
individuals from misbehaviour. <fnref n="319" /> Such rates for incompetence and

<footnote n="316">³¹⁶ Funnell (2001), p. 177, and pp. 1–25.</footnote>

<footnote n="317">³¹⁷ J. Broadbent, and R. Laughlin (2003). ‘Control and legitimation in gov-
ernment accountability processes. The private finance initiative in the UK’,
*Critical Perspectives on Accounting*, Vol. 14, No. 1–2, pp. 23–48.</footnote>

<footnote n="318">³¹⁸ For incompetence: J. Hogan, R. Hogan, and R.B. Kaiser (2010). ‘Management derailment. Personality assessment and mitigation’, S. Zedeck (ed.), *American Psychological Association Handbook of Industrial and Organizational Psychology*, American Psychological Association, Washington, Vol. 3, pp. 555–575, p. 556. For integrity: Kaiser, and Hogan (2010), p. 231.</footnote>

<footnote n="319">³¹⁹ A. Padilla, R. Hogan, and R.B. Kaiser (2007). ‘The toxic triangle. De-
structive leaders, vulnerable followers, and conducive environments’, *Lead-
ership Quarterly*, Vol. 18, No. 3, pp. 176–194.</footnote>
problematic integrity are enough reason to hold managers to account. 320

<table><caption>Figure 8. Board (or Directors) accountability</caption><thead><tr><th colspan="2">Governing Domain</th></tr><tr><th colspan="2">7. Board (or Directors) accountability</th></tr></thead><tbody><tr><td>Direction:</td><td>Vertical</td></tr><tr><td>Source:</td><td>Formal</td></tr><tr><td>Power:</td><td>Strong and weak</td></tr><tr><td>Who</td><td>(Board of) Directors</td></tr><tr><td>To whom:</td><td>External: Shareholders, superior government organizations, and other stakeholders</td></tr><tr><td>About:</td><td>The organization, its behaviour, and the strategic decisions made in relation to its operations</td></tr><tr><td>Procedures:</td><td>Formal</td></tr><tr><td>Standards:</td><td>Law and regulations, organizational charters.</td></tr><tr><td>Consequences:</td><td>Dependent on jurisdictions</td></tr><tr><td>EIM</td><td>Necessary</td></tr><tr><td>Ethics Management</td><td>Compliance and integrity</td></tr></tbody></table>

According to Andrew Keay, this manifestation of accountability concerns constraining organizational executives and boards (ceo's, board of directors, and/or directors of government organizations) to provide an account and an explanation (to an accountor whose

<footnote n="320">320 According to: S. Ackroyd, and P. Thompson (2015). ‘Unruly subjects. Misbehaviour in the workplace’, S. Edgell, H. Gottfried, and E. Granter (eds.), *The Sage Handbook of the Sociology of Work and Employment*, SAGE, London, Chapter 11, pp. 185–204, managerial misbehaviour is ‘the most glaring example of selective myopia’ and ‘there are some indications managerial misbehaviour is becoming more rather than less prevalent.’ (p. 185). The myopia of social research for managerial misbehaviour cannot be sustained, especially when reviewing the data used by Hogan, Hogan, and Kaiser (2010) and Kaiser, and Hogan (2010).</footnote>
identity may differ) about the organization, its behaviour, and the decisions made in relation to its operations. <fnref n="321" /> This manifestation concentrates on [1] strategic, rather than detailed control on organizational self-evaluation and reporting, [2] periodic, formal external evaluation, and [3] on a 'rationalization' of organizational responsiveness. Strategic control emphasizes setting of objectives to establish overall direction. <fnref n="322" /> This manifestation is closely linked with managerial accountability. What is mentioned there about incompetence and integrity is fully applicable to this manifestation.

Boards (and directors) do have a legal responsibility to provide oversight and be accountable for an organization's performance. They are responsible for appropriately governing the resources of the organization and following all legal and ethical standards. Their power is delegated to them by shareholders, superior government organizations, or political administrators. Is the power of shareholders to require accountability relatively weak, that of government organizations or political administrators is strong. They can remove directors when not satisfied with the account given, although that is an extreme punishment. That is not equally true for shareholders of a business organization. They are at a disadvantage when compared with the (members of the board of) directors. They lack the information that is available to the directors, which they need to assess organizational performance or to know how well the organization is really doing. <fnref n="323" /> In theory, shareholders can require all information at any moment in time. In practice, it is almost impossible to get the detailed information that is necessary to eliminate this

<footnote n="321">³²¹ Keay (2015), pp. 57–70.</footnote>

<footnote n="322">³²² Stone (1995), p. 512–514</footnote>

<footnote n="323">³²³ A. Keay, and J. Loughrey (2015), 'Board accountability in corporate governance', *Legal Studies*, Vol. 35, No. 2, pp. 252–279.</footnote>
information asymmetry. <fnref n="324" /> Shareholders do have the power to re-
move a director, but a majority vote need to be obtained. This is
difficult, especially in large organizations where small shareholders
are disorganized and powerless to impose their will. It is much eas-
ier to sell all shares, which demonstrates that the power sharehold-
ers wield is rather weak.

Given the globally evolving regulatory frameworks, a strategy
focused only on profit, without thinking about social consequences
can trigger substantial costs. Larry Ribstein states that the share
price penalty may exceed profits gained from ‘doing wrong’. Most
shareholders do not want ‘their’ business organizations acting in
ways that trigger penalties, liabilities, and future regulation. The
risks for not disclosing (regulatory) risks are too high. Directors and
managers might engage in nefarious activities for profit, especially
if they are sure of not being caught or penalized and might want to
hide substantial risks. But this is not because managers are exces-
sively accountable to shareholders. It is because they are ‘not ac-
countable enough’. <fnref n="325" /> The Volkswagen diesel emission scandal of
2015 is an example of ‘not accountable enough’. It involved cheating

<footnote n="324">³²⁴ S.H. Han, M. Kim, D.H. Lee, and S. Lee (2014), ‘Information asymmetry, corporate governance, and shareholder wealth. Evidence from unfaithful disclosures of Korean listed firms’, *Asia-Pacific Journal of Financial Studies*, Vol. 43, No. 5, pp. 690–720.</footnote>

<footnote n="325">³²⁵ L.E. Ribstein (2005). ‘Accountability and responsibility in corporate governance’, *Notre Dame Law Review*, Vol. 81, No. 4, pp. 1431–1493, pp. 1444–1445. Keay, and Loughrey (2015), pp. 258–259. The power of shareholders differs in various jurisdictions. In the United Kingdom, for instance, the shareholders cannot interfere except in very limited circumstances. In the United States, not even a unanimous vote of shareholders can control the directors, which explains why asking directors to be really accountable will always be problematic. Stating that they are ‘not accountable enough’ is correct and is incentivized by the prevailing jurisdiction.</footnote>
of consumers, taxpayers, governments, and shareholders and indi- cates how ineffective the control systems were. It is unlikely that the shareholders of Volkswagen would willingly risk billions of dol- lars of value, bringing the company to an almost bankruptcy. It is likely that Volkswagen was an example of short-termism, in which managers started cutting corners to meet rising sales targets and ex- pected profitability. The absence of integrity-based accountability systems is clear. 326 Board accountability, thus, is, just like other gov- erning manifestations, not as straightforward as it seems, with many bottlenecks and problems to solve.

<table><caption>Figure 9. Political accountability</caption><thead><tr><th colspan="2">Governing Domain</th></tr><tr><th colspan="2">8. Political accountability</th></tr></thead><tbody><tr><td><em>Direction:</em></td><td>Vertical and horizontal</td></tr><tr><td><em>Source:</em></td><td>Formal and informal</td></tr><tr><td><em>Power:</em></td><td>Strong and (relatively) weak</td></tr><tr><td><em>Who</em></td><td>Government organizations; Business organizations (indirectly)</td></tr><tr><td><em>To whom:</em></td><td><em>External:</em> Parliament, Ministers, Secretaries; society at large.</td></tr><tr><td><em>About:</em></td><td>Development and operationalization of policies and decisions</td></tr><tr><td><em>Procedures:</em></td><td>Formal, but with countless informal backrooms in which business organizations participate</td></tr><tr><td><em>Standards:</em></td><td>Law and regulations</td></tr><tr><td><em>Consequences:</em></td><td>Political responsibility and its consequences (depending on jurisdiction)</td></tr><tr><td><em>EIM</em></td><td>Necessary</td></tr><tr><td><em>Ethics Management</em></td><td>Compliance and integrity</td></tr></tbody></table>

<footnote n="326">326 S.D. Carter, D. Crooks, I. Wise, and S. Beyer (2018). ‘Volkswagen – The failure of perfection and moral hazard. What price victory?’, *International Journal of Business and Applied Sciences*, Vol. 7, No. 1, pp. 35–48.</footnote>
This manifestation is a very complex one because of it being in-
tertwined with, what is sometimes called, representative of demo-
cratic accountability, a vertical accountability relationship between
citizens and elected representatives (members of parliament or gov-
ernment officials), which comes into being through democratic elec-
tions. That is a relationship in which citizens cede power to politi-
cians who in turn need to explain and justify their actions to their
electorate. The citizens have the right to sanction political leaders
by voting them in or out of office. <fnref n="327" /> Developments within the rep-
resentative system cross borders with political accountability.

In its ‘pure sense’ this political manifestation is formally *only* ap-
plicable to government organizations, be they national, regional, or
local. According to Antonio Bar Cendón, political accountability
takes place in a double dimension: vertical and horizontal. In its
vertical dimension, political accountability is a relationship that
links the government administration with the minister and/or sec-
retary politically responsible for that administration. In its horizon-
tal dimension, it is the relationship between government and parlia-
ment. That relationship may also include some of the positions at
the top of the administration, depending on the legal and constitu-
tional provisions of a country. <fnref n="328" />

Political accountability allows ministers and secretaries to con-
trol the large government administration that implements the gen-
eral policies that politicians decide upon. These policies, however,
are only guidelines for meeting political goals which allow the ad-
ministration a lot of leeway in a wide range of activities. Ministers
and secretaries have various priorities, lack of time, and cognitive
constraints. Hence, they can attend to a limited number of deci-

<footnote n="327">³²⁷ Bovens (2007a), p. 455; Peruzotti, and Smulovitz (2006), p. 6.</footnote>

<footnote n="328">³²⁸ Bar Cendón (2000), p. 29.</footnote>
sions, policies, actions, and transactions. It is not uncommon that
employees seek to block, divert, and slow-down their political
‘bosses’. Balancing complex rules and procedures and allowing the
administration discretion to use their expertise, is difficult. <fnref n="329" /> But
ministers and secretaries are accountable for the workings of a bu-
reaucracy, even if they have no knowledge of infraction(s). They are
dependent on the information handed to them by the administra-
tion. If their account is deemed unsatisfactory, it could, ultimately,
lead to their resignation. For this political manifestation of account-
ability to be effective, both a strong administrative manifestation
and integrity-based ethics management are necessary.

Parliament is the only accountability institution directly elected
by citizens and directly accountable to it through the ballot box.
Viewed as an accountor-accountee relationship, in parliamentary
democracy citizens delegate their law-making powers to parliamen-
tarians who, in turn, delegate that power to several delegates who
form the government in a ‘chain of delegation.’ In return, there is
accountability from the government, through parliament, to the cit-
izens — the ultimate accountors. <fnref n="330" /> This accountability relation-
ship, however, is not as strong as it seems. It is claimed that the role
of parliament in forming governments has damaged its role in hold-
ing them to account and to make the government behave. <fnref n="331" />

The influence of business organizations on politics muddies the
water further, just like that of bureaucrats and interest groups. It is

<footnote n="329">³²⁹ W.T. Bianco, and D.T. Canon (2015). *American Politics Today*, W.W. Norton & Company, New York, sixth edition, Chapter 12, pp. 454–487.</footnote>

<footnote n="330">³³⁰ Strøm (2000), pp. 267–268.</footnote>

<footnote n="331">³³¹ P. Larking (2012). ‘Ministerial accountability to parliament’, K. Dowding, and C. Lewis, *Ministerial Careers and Accountability in the Australian Commonwealth Government*, ANU Press, Canberra, Chapter 5, pp. 95–114, especially 95–99.</footnote>
impossible to hold them formally to account. Citizens are not rep-
resented in policy networks in which government administration,
experts, interest groups, and ‘big corporations’ participate. These
groups, however, do not represent citizens, are not constrained by
electoral pledges, and do not have to anticipate electoral sanctions.
There are no formal mechanisms to hold them to account. <fnref n="332" /> An-
other problem is the temptation of self-interest by politicians that
leads them to continuous moving between government and business
spheres. These representatives are disguising their interests and are
mystifying accountability with the risk of negating its effects. <fnref n="333" />

It is this participation of business organizations in political net-
works and the combination of government and business spheres
that creates troublesome problems for political accountability. Busi-
ness organizations are only indirectly linked with the political man-
ifestation of organizational accountability, but there are no ‘eyes’
linked to this manifestation for them to account to. There is, how-
ever, intense scrutiny of business organizations and their influence
on politics by many interest groups that are very diverse in nature.
They hold business organizations to account with informal (but po-
tentially strong) social accountability mechanisms.

The social networks domain

This domain is about the way peers (organizations and employ-
ees) and professional associations keep organizations and individual

<footnote n="332">³³² Y. Papadopoulos (2007). ‘Problems of democratic accountability in network and multilevel governance’, *European Law Journal*, Vol. 13, No. 4, pp. 469–486; Willems, and Van Dooren (2011), pp. 517–518.</footnote>

<footnote n="333">³³³ G. Lehman, and K. Thorne (2015). ‘Corruption, criminality and the privatised state. The implications for accounting’, *Accounting Forum*, Vol. 39, No. 4, pp. 366–370.</footnote>
employees accountable for their behaviour. It groups two manifestations of accountability: [9] peer accountability, and [10] professional accountability.

<table><caption>Figure 10. Peer accountability</caption><thead><tr><th colspan="2">Social Networks Domain</th></tr><tr><th colspan="2">9. Peer accountability</th></tr></thead><tbody><tr><td>Direction:</td><td>Horizontal</td></tr><tr><td>Source:</td><td>Informal</td></tr><tr><td>Power:</td><td>(Relatively) strong</td></tr><tr><td>Who</td><td>Peers (organizations, team members)</td></tr><tr><td>To whom:</td><td>External: peer organizations<br>Internal: team members, peer groups</td></tr><tr><td>About:</td><td>Mutual monitoring of performance and behaviour in peer groups</td></tr><tr><td>Procedures:</td><td>Informal, based on informal feedback</td></tr><tr><td>Standards:</td><td>Informal agreements between peers; peer norms</td></tr><tr><td>Consequences:</td><td>Loss of esteem and reputation</td></tr><tr><td>EIM</td><td>Not necessary</td></tr><tr><td>Ethics Management</td><td>Integrity</td></tr></tbody></table>

Scientists have long been interested in the impact of the social, educational, and workplace environment on employee behaviour. There is a growing amount of literature that suggests than the influence peers have on the behaviour of individual employees is very important. <fnref n="334" /> According to Robert Goodin, peer accountability is

<footnote n="334">³³⁴ R. Holden, M. Keane, and M. Lilley (2021). ‘Peer effects on the United States supreme court’, *Quantitative Economics*, Vol. 12, No. 3, pp. 981–1019; J. Jansen Lockett, L. Barkley, J. Stichler, J. Palomo, B. Kik, C. Walker, J. Donnelly, J. Wilson, J. Sanborn, and N. O’Byrne (2015). ‘Defining peer-to-peer accountability from the nurse’s perspective’, *JONA. The Journal of Nursing Administration*, Vol. 45, No. 11, pp. 557–562; B.J.</footnote>
‘based on mutual monitoring of one another’s performance within a network of groups.’ <fnref n="335" /> Peer accountability occurs when employees (or organizations within the same organizational network) are accountable to their peers. Although there is a lot of criticism possible on March and Olsen’s theory of the logic of appropriateness, it may be possible to apply this theory to peer accountability. Under this theory, ‘actors seek to fulfil the obligations encapsulated in a role, an identity, a membership in a political community or group, and the ethos, practices and expectations of its institution. Embedded in a social collective, they do what they see as appropriate for themselves in a specific type of situation.’ <fnref n="336" /> It is inherently social and ‘soft’ and relies on the integrity of colleagues, be they organizations or individuals. Networks of organizations and/or individuals do control its members by ‘mutual monitoring among a band of well-intentioned coeuals.’ <fnref n="337" />

Peer accountability is inherently informal; it lacks formal sanctions. Standard setting, feedback, and appropriate behaviour are rooted in the capacities of networks to develop social norms of engagement, and to control these through non-coercive means like approval and disapproval. It could backfire, however, when social pressure is strong. Individuals may refuse to submit to pressures. <fnref n="338" />

<footnote>Moy (2021). ‘Can social pressure foster responsiveness? An open records field experiment with mayoral offices’, *Journal of Experimental Political Science*, Vol. 8, No. 2, pp. 117–127.</footnote>

<footnote n="335">³³⁵ Goodin (2003), p. 378.</footnote>

<footnote n="336">³³⁶ J. March, and J.P. Olsen (2011). ‘The logic of appropriateness’, R.E. Goodin (ed.), *The Oxford Handbook of Political Science*, Oxford University Press, Oxford, pp. 478–497, p. 478.</footnote>

<footnote n="337">³³⁷ Goodin (2003), p. 392.</footnote>

<footnote n="338">³³⁸ Z. Terechshenko, C. Crabtree, K. Eck. and C.J. Fariss (2019). ‘Evaluating the influence of international norms and shaming on state respect for</footnote>
Peer accountability is about esteem, and reputation, the intangible hand, as argued by Geoffery Brennan and Philip Pettit.<fnref n="339" /> Colin Scott argues in the same vein that the fear of losing one’s reputation drives the effects of peer accountability. <fnref n="340" /> It does not matter if peers are organizations in a political or business network or employees in a team or work group. Organizations that lose esteem or reputation may find it more difficult to collaborate, share resources, or find partners. The commitment to respect peers (employees as well as organizations) and to behave appropriately, the unwillingness to let peers down, and the fear to lose a reputation, is very effective, although extremely difficult to control. Peers will conform to the expectations of the relational climates they are part of. Social approval is more important than the potential effectiveness or outcomes of a decision. This could mean a risk for accountability: if unethical and non-compliance behaviour is deemed necessary for the ‘good’ of the group of peers it might be perceived as acceptable. Expectations in relational climates do not always conform with organizational expectations and ‘mores’. <fnref n="341" />

Developing strong social relationships within organizations and increasing team understanding of what behaviour is expected in the organization should lead to compliance or conformity to expectations, especially when organizational leaders continuously emphasize the expected ethical behaviour, and integrity-based ethics management is prevalent within the organization.

<footnote>rights. An audit experiment with foreign embassies', *International Interactions*, Vol. 45, No. 4, pp. 720-735.</footnote>

<footnote n="339">³³⁹ G. Brennan, and P. Pettit (2004). *The Economy of Esteem. An Essay on Civil and Political Society*, Oxford University Press, Oxford, especially p. 5, pp. 245-321. See also (about reputation): Busuioc, and Lodge (2017).</footnote>

<footnote n="340">³⁴⁰ Scott (2006), pp. 180-181.</footnote>

<footnote n="341">³⁴¹ Lerner, and Tetlock (1999), pp. 256-257. See: Van Bussel (2020), pp. 32.</footnote>
<table><caption>Figure 11. Professional accountability</caption><thead><tr><th colspan="2">Social Networks Domain</th></tr><tr><th colspan="2">10. Professional accountability</th></tr></thead><tbody><tr><td>Direction:</td><td>Horizontal and vertical</td></tr><tr><td>Source:</td><td>Informal and formal</td></tr><tr><td>Power:</td><td>(Relatively) strong</td></tr><tr><td>Who</td><td>Professionals</td></tr><tr><td>To whom:</td><td>External: Professional organizations<br>Internal: Employers</td></tr><tr><td>About:</td><td>Professional behaviour</td></tr><tr><td>Procedures:</td><td>Professional code of behaviour and ethics</td></tr><tr><td>Standards:</td><td>Professional (dependent of specific profession)</td></tr><tr><td>Consequences:</td><td>Loss of reputation; reprimand, censure, suspension</td></tr><tr><td>EIM</td><td>Recommended (where possible)</td></tr><tr><td>Ethics Management</td><td>Integrity and compliance</td></tr></tbody></table>

Professionals lay claim to expert knowledge beyond the understanding of non-professionals, implicating that actions can be fully assessed only by fellow-professionals. Barbara Romzek and Melvin Dubnick characterized professional accountability as ‘deference to expertise’, where organizations rely on an experts’ technical knowledge and where external scrutiny is inappropriate. 342 This last statement is questionable. Professional accountability takes place in the world of professions, outside an organizations’ walls but also within its accountability framework. Professional are accountable to their organizations for their decisions. But they are not sanctioned for results (patients dying, or lawyers losing), but for ‘malpractice’ in their processes, using improper means to achieve results. 343 Professionals are governed by a set of technical and/or professional norms

<footnote n="342">342 Romzek, and Dubnick (1994), pp. 272–271.</footnote>

<footnote n="343">343 Deleon (1998), pp. 548–549.</footnote>
and practices to define behaviour and performance. They are subject to these norms but are autonomous in their work and act according to their own criteria and knowledge. These professional rules and principles have both a technical and an ethical dimension. It is common for professions to have their own codes of behaviour and/or ethics. Professional organizations establish mechanisms for their application and control. These controls, where they exist, tend to focus on compliance with these professional rules and principles. <fnref n="344" /> Effective and reliable scrutiny requires review boards or disciplinary committees containing expert members of the same profession. <fnref n="345" /> Professional bodies implement codes with (binding) standards for acceptable behaviour.

In the last decades the reputations and performance of experts are being questioned and diminished trust in professionals seems to be the result. The evidence, however, that professionals or professional institutions are less trustworthy is elusive. What there is, is evidence that ‘we say we trust less’ in polls and talk shows. Repeated messages do not make it true. <fnref n="346" /> But that there is a ‘culture of suspicion’ is without doubt and this culture, extensively nurtured by social media, should stimulate external, formal professional review bodies to pull the reigns and force their professionals to comply to the defined ethical and behavioural standards that they have accepted but often only lukewarmly implemented in practice.

## The societal domain

This domain groups one manifestation of accountability: [11] social and environmental accountability. This manifestation is about

<footnote n="344">³⁴⁴ Bar Cendón (2000), pp. 39–40.</footnote>

<footnote n="345">³⁴⁵ Bovens (2007), p. 456.</footnote>

<footnote n="346">³⁴⁶ O’Neill (2002), pp. 43–45.</footnote>
all the (unspecified) calls for (government of business) organizations to account for their behaviour to the general public ('society at large') or, at least, to civil interest groups, charities, and associations of clients. Within this domain, many questions arise about the way organizations manage the environment, human rights, labour circumstances, perceived influence on politics, and so on.

<table><caption>Figure 12. Social and Environmental accountability</caption><thead><tr><th colspan="2">Societal Domain</th></tr><tr><th colspan="2">11. Social and Environmental accountability</th></tr></thead><tbody><tr><td>Direction:</td><td>Horizontal</td></tr><tr><td>Source:</td><td>Informal</td></tr><tr><td>Power:</td><td>Weak and strong</td></tr><tr><td>Who</td><td>Organizations, (boards of) Directors</td></tr><tr><td>To whom:</td><td>External: 'Society at large', interest groups, social networks, and the media</td></tr><tr><td>About:</td><td>Social and environmental behaviour</td></tr><tr><td>Procedures:</td><td>No procedures, but societal protest and upheaval, and often legal procedures</td></tr><tr><td>Standards:</td><td>No standards, but opinions</td></tr><tr><td>Consequences:</td><td>Reputational damage, legal procedures</td></tr><tr><td>EIM</td><td>Recommended (where possible)</td></tr><tr><td>Ethics Management</td><td>Integrity and compliance</td></tr></tbody></table>

This manifestation involves answering concerns of unspecified citizens, customers, and/or interest groups through various audiences (as social media, newspapers, and other media) about activities of government or business organizations. Those concerns can be very diverse: labour situations, the political interference of business organizations, corruption, human rights, health care, tax evasion, providing of services by government organizations, behaviour of public officials, and, recently, the environmental behaviour of or-
ganizations. It is a horizontal, largely informal mechanism of con-
trol of organizations that rests on the actions of temporarily groups
of citizens, an array of citizen's associations and (social) media.
These actions try to monitor and expose both government and busi-
ness organizations for perceived or real wrongdoing. They will in-
volve oversight agencies, activate legal action, mobilize social media
and media organizations, and put pressure on political parties and
members of parliament.

Social and environmental accountability relies on civil society to exert influence on organizations. Its mechanisms contribute to the enforcement of the rule of law, but also try to use reputational concerns of organizations and employees. <fnref n="347" /> They are not blunt instruments used to evaluate all the actions and actors within government and business organizations, but allow for selective control, signaling, and sanctioning of specific actors or behaviours. Although they can be very strong instruments, they are extremely demanding in terms of participatory efforts. If participation is lacking, this manifestation's actions are only very weak controls on organizational behaviour. The mechanisms used are 'demand-driven and operate bottom-up', like demonstrations, protests, and investigative journalism. <fnref n="348" /> In recent years, the use of participatory data collection and analysis tools have led to more intense accountability practices. These include, for example, expenditure tracking and citizen and customer monitoring. Mechanisms of social and environmental ac-

<footnote n="347">³⁴⁷ Peruzzotti, and Smulovitz (2006), p. 10–11.</footnote>

<footnote n="348">³⁴⁸ C. Malena, R. Forster, and J. Singh (2004). *Social Accountability. An introduction to the concept and emerging practice*. Social Development Papers, No. 76, World Bank, Washington, p. 3 Online source, retrieved on November 19, 2021, from:
https://documents1.worldbank.org/curated/en/327691468779445304/pdf/310420PAPER0So1ity0SDP0Civic0no1076.pdf</footnote>
countability are intended both to complement and enhance conven-
tional mechanisms of accountability.

Most of these informal actions and mechanisms rely upon public
pressure, because the possibilities of judgement and sanctioning are
lacking. <fnref n="349" /> These very public actions, however, can result in public
relation disasters for the ‘victims’ of this manifestation of organiza-
tional accountability. <fnref n="350" /> Government as well as business organiza-
tions try to contain the effects of social accountability by adhering
to corporate social responsibility (CSR), that encompasses issues re-
volving around the interaction with society. It covers issues like eth-
ics, philanthropy, and community involvement, product safety, hu-
man rights, equal (labour) opportunities, and environmental activi-
ties. CSR is linked with social reporting, the communication of so-
cial effects of the (economic) actions of organizations to particular
interest groups within society and to society at large. It stresses the
need for socially relevant organizational behaviour. <fnref n="351" />

CSR deals especially with social obligations imposed on organi-
zations by international law principles, making CSR itself con-
trolled by the legal manifestation of organizational accountability.
Most organizations try to comply to minimum standards for social
obligations using their reputation to impress that they are a solution
for regulation and societal problems. Although that is popular view
within government circles, business as well as government organi-
zations are, paradoxically, also considered by the general public as

<footnote n="349">³⁴⁹ Bovens (2007), p. 457.</footnote>

<footnote n="350">³⁵⁰ W.S. Laufer (2003). 'Social accountability and corporate greenwashing', *Journal of Business Ethics*, Vol. 43, No. 3, pp. 253-261.</footnote>

<footnote n="351">³⁵¹ S. Seifi, and D. Crowther (2018). ‘The need to reconsider CSR’, D. Crowther, and S. Seifi (eds.), *Redefining Corporate Social Responsibility*, Emerald Publishing, Bingley, Chapter 1, 1–14.</footnote>
causing and permitting environmental disasters, financial and fiscal scandals, social ills, and corruption. <fnref n="352" />

It is an important reason why CSR-policies and expressed pro-social behaviour of many organizations are not believed and trusted by the public at large. <fnref n="353" /> It is understandable: it is a largely unregulated and unchecked domain unless or until a failure is disclosed. ‘Compliance’ often devolves into a creative blending of risk and reputation management when organizational leadership does not enforce integrity-based ethics management. <fnref n="354" /> Which was what happened in the financial crisis of 2008: many financial institutions had CSR-policies in place when they fell victim of their myopia. <fnref n="355" />

Environmental aspects within CSR, especially, are treated very critically by many interest groups and large segments of the general public. Accountability for environmental activities is part of social accountability because there are, many environmental laws notwithstanding, not (yet) common accountability structures of ac-

<footnote n="352">³⁵² Minimum standards: P. Park (2009). ‘Perspectives of lawyers in practice on CSR’, S.O. Idowu, W.L. Filho, *Professionals’ Perspective of Corporate Social Responsibility*, Springer, Berlin-Heidelberg, Chapter 2, pp. 33–47. Paradox: A.G. Scherer, and G. Palazzo (2008). ‘Globalization and corporate social responsibility’, A. Crane, A. McWilliams, D. Matten, J. Moon, and D. Siegel (eds.), *Oxford Handbook of Corporate Social Responsibility*, Oxford University Press, Oxford, pp. 413–431.</footnote>

<footnote n="353">³⁵³ H. Rim, and S. Kim (2016). ‘Dimensions of corporate social responsibility (CSR) skepticism and their impacts on public evaluations toward CSR’, *Journal of Public Relations Research*, Vol. 28, No. 5–6, pp. 248–267.</footnote>

<footnote n="354">³⁵⁴ Laufer (2003), pp. 253–261.</footnote>

<footnote n="355">³⁵⁵ C. Jacob (2012). ‘The impact of financial crisis on corporate social responsibility and its implications for reputation risk management’, *Journal of Management and Sustainability*, Vol. 2, No. 2. Online source, retrieved on November 19, 2021, from: https://www.ccsenet.org/journal/index.php/jms/article/view/18126.</footnote>
countors and accountees in place. Organizational leaders face grow-
ing public demand to reduce the pollutants their organizations pro-
duce and to increase their environmentally responsible activities. It
is becoming a very important dimension and subset of CSR. <fnref n="356" />
Damage done to the environment resulted in the attention of inves-
tors and the general public in environmental responsibility. <fnref n="357" /> En-
vironmental challenges are complex and diverse in nature. Climate
change, acidification of the oceans, declining biodiversity, and ozon
depletion in the stratosphere illustrate the environmental problems
of modern civilization. <fnref n="358" /> Business organizations are central to this
process as they are the engines of the global economy, continuously
driven by the impossible objective of infinite growth. The resulting
environmental damage has led to social criticism, political mobili-
zation, and government regulations. As was correctly asserted by
Roger Burritt and Stephen Welch, accountability for environmental
activities ‘cannot function without information being provided to
stakeholders about actual and potential environmental perfor-
mance’. <fnref n="359" /> Alon Lischinsky and Annika Sjölander affirm that or-

<footnote n="356">³⁵⁶ M. Kitzmueller, and J. Shimshack (2012). ‘Economic perspectives on corporate social responsibility’, *Journal of Economic Literature*, Vol. 50, No. 1, pp. 51–84.</footnote>

<footnote n="357">³⁵⁷ S. Castaldo, F. Perrini, N. Misani, and A. Tencati (2009). ‘The missing link between corporate social responsibility and consumer trust. The case of fairtrade products’, *Journal of Business Ethics*, Vol. 84, No. 1, pp. 1–15.</footnote>

<footnote n="358">³⁵⁸ W. Steffen, K. Richardson, J. Rockström, S.E. Cornell, I. Fetzer, E.M. Bennett, R. Biggs, S.R. Carpenter, W. de Vries, C.A. de Wit, C. Folke, D. Gerten, J. Heinke, G.M. Mace, L.M. Persson, V. Ramanathan, B. Reyers, S. Sörlin (2015). ‘Planetary boundaries. Guiding human development on a changing planet’, *Science*, Vol. 347, No. 6223, pp. 736: 1–10.</footnote>

<footnote n="359">³⁵⁹ R.L. Burritt, and S. Welch (1997). ‘Accountability for environmental performance of the Australian Commonwealth public sector’, *Accounting, Auditing & Accountability Journal*, Vol. 10, No. 4, pp. 532–561, p. 534.</footnote>
ganizations must do business within the expectations and norms of society, that this demands public scrutiny of environmental performance and the disclosure of information about that performance.

At the same time, many organizations, be they governmental or business, try to manipulate the outcomes of public debates about environmental issues. <fnref n="360" /> They have advanced strategies in place to provide information about their environmental performance. <fnref n="361" /> In their annual reports financial disclosures complement with sections concerning social and environmental metrics. The public tends to regard these metrics as biased and as a consequence, organizations try to enhance the credibility of their environmental activities by circulating metrics through ‘independent’ sources. <fnref n="362" /> There is a risk that news media are becoming dependent on the public relations activities of private interests and that environmental news, especially, is manipulated to boost the financial and reputational interests of business organizations. Poor environmental performance, after all, impacts share prices, brings unwanted publicity and, possible, government interference. So, why not using a public relations budget to manipulate communication about environmental activities and mixing public relations with propaganda? It happens. Public

<footnote n="360">³⁶⁰ A. Lischinsky, and A. Sjölander (2014). ‘Talking green in the public sphere. Press releases, corporate voices and the environment’, *NORDI-COM Review. Nordic Research on Media and Communication*, Vol. 35, Special Issue, pp. 125–139.</footnote>

<footnote n="361">³⁶¹ At least for business organizations: Laufer (2003); H. Lehtimäki, J. Kujala, and A. Heikkinen (2011). ‘Corporate responsibility in communication. Empirical analysis of press releases in a conflict’, *Business Communication Quarterly*, Vol. 74, No. 4, pp. 432–449.</footnote>

<footnote n="362">³⁶² A. Hansen (2010), ‘Making claims and managing news about the environment’, A. Hansen, *Environment, Media and Communication*, Routledge London, Chapter 3, pp. 36–74.</footnote>
relations are, after all, many times used to ‘clean the organizational image’, even using manipulation of the public. <fnref n="363" />

As long as organizations do not have to grant public access to
independently verified information that validates their metrics, this
dimension of CSR is difficult to evaluate. But reputations are valu-
able, and just for that reason social and environmental accountabil-
ity could make organizations more accountable. If the effects of
public disapproval impact the reputational capital of an organiza-
tion (and its shareholder value), it represents a sanction that strongly
influences the possibility of success in the market.

A framework: some conclusions

The framework of accountability manifestations can assist or-
ganizational leaders in aligning their governing structures with the

<footnote n="363">³⁶³ I.K. Idris (2019). ‘Propaganda in contemporary public relations’, *Proceedings of the 1st International Conference on Anti-Corruption and Integrity (ICOACI)*, September 3, 2019, Research Synergy Foundation, Jakarta, pp. 82–89. Public relations want ‘to mould public opinion and behaviours by manipulating a human’s basic motives and desires.’ (p. 89). According to Idris, in dominant public relations research public relations have been conceptualized into two-way mutual dialogic communication, as is reflected in the many definitions of what public relations are. See for instance: S. Roberts-Bowman (2020). ‘What is Public Relations?, A. Theaker (ed.), *The Public Relations Handbook*, Routledge, Abingdon-New York (sixth edition), chapter 1, pp. 3–24. Idris emphasizes that recent research shows a lack of two-way dialogic communication, specifically on the website and social media platforms. The conclusion of Idris is that the three fundamental elements of propaganda (manipulation, well-planned intention, and one-way communication flow) are still commonly practiced in public relations. My conclusion that public relations are often used to ‘clean the organizational image’ is not as farfetched as may initially be thought.</footnote>
(external) expectations of accountability. The complex systems or-
ganizations turn out to be are dynamic networks of multi-actor and
multi-directional interactions, functioning in hostile and dynamic
environments, with erratic strategic decisions made by organiza-
tional leaders. In such systems, it is never clear who is, in the end,
responsible and accountable for a decision, an action, a transaction,
or a policy. There are ‘many hands’ that participate in the making,
implementation, and processing of such decisions, actions, transac-
tions, and policies. It is clear that in such organizations, information
is core to everything organizations do, and that it should be metic-
ulously governed and managed. The overall assumption in manage-
ment literature that information is managed appropriately is, how-
ever, incorrect. In addition, in such complex environments the as-
sumptions in accountability literature about rational decision-mak-
ing and linear cause-effect relationships, are not viable. Collective
views of accountability *do* make a lot of sense in such organizations
and are, possibly, the only solution to hold complex organizations
to account.

Where does this leave the framework of manifestations of organ-
izational accountability defined above?

First, the manifestations of organizational accountability in the
framework *cannot be ranked in order of importance*. All of them may
have serious organizational consequences. It is a subjective consid-
eration of organizational leaders how those manifestations should
be prioritized, and in which order. In daily practice, most attention
seems to be paid to formal manifestations with ‘strong’ power, alt-
hough those do not need to be the ones with the most severe conse-
quences. Organizational leaders can use the framework to decide in
which order these manifestations are prioritized, based on an anal-
ysis of the (un-)acceptability of consequences.
Second, although all manifestations in the framework are about
'being accountable', and they are presented as (as I have stated be-
fore) eleven ideal types in which a linear cause-effect relationship
seems clear, *in reality ideal types do not exist*. As Tom Campbell al-
ready determined in 1981, ideal types are selective oversimplifica-
tions to understand the nature of the subject of simplification. In
ideal types, relations of linear cause and effect are *assumed*. How-
ever, assumptions may not be true.<fnref n="364" /> In complex organizations lin-
ear causes and effects often are extremely difficult to detect. It is,
many times, hardly possible to pinpoint the direct cause(s) of an
effect (if it is even possible to pinpoint a specific effect itself!), the
complex and varying models of causation notwithstanding. <fnref n="365" /> Or-
ganizational leaders may use the framework to analyse the existing
possibilities within its governance structure to identify cause-effect
relationships, and the responsible and accountable individuals, or,
when not possible, accept the fact that the organization (or maybe
better: its (board of) directors and other senior managers) will be
accountable as a collective.

Third, although it is difficult to rank them, there is *one manifestation that influence success or failure of all other manifestations: peer accountability*, based on the relational climates in which employees work, function, and socialize. This informal manifestation of organizational accountability is about how employees in the relational climates or organizations are socialized, how they are stimulated to behave, how that behaviour is monitored by the behavioural standards of the team, group, or place of work, and how group monitoring and social control pressure employees to be accountable to their

<footnote n="364">³⁶⁴ T. Campbell (1981). *Seven Theories of Human Society*, Clarendon Press, Oxford, pp. 175–177.</footnote>

<footnote n="365">³⁶⁵ Lindberg (2013), pp. 16–17.</footnote>
peers about their behaviour. When these behavioural standards do
not conform with the required organizational standards for the
other manifestations of accountability, there are compliance risks.
Organizational leaders need to ensure that managers of teams,
groups, or places of work align organizational expectations and re-
quirements for behaviour with the expectations and requirements
adhered in the teams, groups, and places of work they manage. Of
all the manifestations of organizational accountability, this manifes-
tation needs to be addressed continuously.

Fourth, although defined as manifestations of accountability, it
is good to remember that *they are, at the same time, manifestations of
performance*. This seems to be contradictory, but it is not in reality.
Accountability and performance both are objectives of organiza-
tional governance and need to be balanced to be effective. If one of
them is dominant, it will have negative effects on the other objec-
tive. Extremely performance-driven organizations will have prob-
lems with the accountability objective, just like extremely account-
ability-driven organizations will have problems with performance.
Accountability and performance are two sides of the same coin.
When one side of the coin is a manifestation of organizational ac-
countability, the other side of the coin is a manifestation of organi-
zational performance. <fnref n="366" /> The manifestations of organizational ac-

<footnote n="366">³⁶⁶ As has been proposed in: G.J. van Bussel, F.F.M. Ector, P.M.A. Ribbers, and G.J. van der Pijl (1999). 'Work- or documentflow. The document revolution? Archival documents as trigger for process improvement', J.P. Heje, C. Ciborra, K. Kautz, c.s. (ed.), *Proceedings of the 7th European Conference on Information Systems Copenhagen Business School*, 23-25 June 1999, ECIS, Copenhagen, I, pp. 55-69; and G.J. van Bussel, F.F.M. Ector, G.J. van der Pijl, P.M.A. Ribbers (2001). 'Building the record keeping system (RKS). Process improvement triggered by management of archival documents', J.P. Sprague (ed.), *Proceedings of the 34th Hawaii International Con-</footnote>
countability do have matching manifestations of organizational performance. Just like any other manifestation, product-services *accountability*, for instance, will be matched by a manifestation of product-services *performance*. Organizational leaders can use the framework to analyse the performance manifestations matching the accountability ones, decide on the performance and accountability criteria needed to realize a balance, and implement these in governance structures like rules and routines.

Fifth, the framework denotes the ethics management approaches needed for all manifestations. *Both compliance-based and integrity-based ethics management are necessary to meet external expectations of accountability*. Nine manifestations require integrity-based ethics management. It can no longer be maintained that only compliance-based ethics management is necessary. Organizational leaders will need to also implement integrity-based ethics management in their organizations. That is not a *choice*, it is a *necessity!* Only implementing compliance-based ethics is insufficient to be really accountable in complex organizations. It may result in symbolic and repetitive accountability relationships that develop into yearly rituals that do not cover anything that is part of really 'being accountable.'<sup>367</sup> Added to this, for the only manifestation that influences success or failure of all other manifestations of accountability, peer accountability, integrity-based ethics is the only possibility. It is an informal accountability manifestation that is ignored by compliance mecha-

<footnote>*ference on System Sciences*, HICCS, Maui, Vol. 8, pp. 8060. Extensively elaborated in: G.J. van Bussel, and F.F.M. Ector (2009). *Op Zoek naar de Herinnering. Verantwoordingssystemen, Content-Intensieve Organisaties en Performance (In Search for Remembrance. Accountability Systems, Content-Intensive Organizations, and Performance)*, Van Bussel Document Services, Helmond. For an English summary, view pp. 459–467.</footnote>

<footnote n="367"><sup>367</sup> Schillemans, and Bovens (2011), pp. 6–8.</footnote>
nisms. Stimulating behaviour to conform to expectations of integ-
rity and continuously evaluating this behaviour in the context of
their relational climates and the organizational ethical code may be
the only possibility organizational leaders have to address peer be-
haviour.

Sixth, *all manifestations of accountability need information, and, with one exception, information management*. Governance is, as I mentioned before, about information, as are its two objectives. Without information both performance and accountability cannot be properly managed. The manifestations are guidelines for enterprise information management that indicate which information is crucial for the organization to allow for performance and accountability. Organizational leaders should consider information to be a business asset governed and managed just as all other crucial business assets. Their information governance should be focused on the information within all interactions in business processes. They cannot ignore information any longer. Not managing information in complex organizations is a recipe for (reputational) disaster.

Seventh, and last, the eleven manifestations of organizational
accountability *are about external expectations about how organiza-
tions should be accountable for the ways they affect their environment.
It is society asserting itself on organizations*. Society will always have
an effect on organizations but in a complex world those expecta-
tions of accountability are evolving. My last manifestation, social
and environmental accountability is a receptacle of many informal
issues that may evolve into separate formal accountability manifes-
tations when laws and regulations ask organizations to ‘be account-
able.’ Eleven manifestation may become twelve or thirteen manifes-
tations in five years. It is a representation of extremely complex and
fluid expectations that ‘society’ expects organizations to satisfy. Or-
ganizational leaders need to satisfy the expectations of their stake-
and shareholders to realize performance but also the fluid expecta-
tions of society-at-large in ‘being accountable.’ They have to bal-
ance their organizational governance in such a way that the annual
performance and accountability metrics are up to expectations. Or-
ganizational governance is a balancing act between its both objec-
tives. The only way to even come close to such a balance is to mix
the rationalities for integrity and compliance into the behavioural
norms and standards expected of all employees and to continuously
monitor and evaluate this behaviour against those norms and stand-
ards. What is needed is a strategic approach to both accountability
and behaviour within organizational governance.
# 6

## A STRATEGIC APPROACH

*
Organizations are, just like their environments, constantly in flux. They are open systems that seem stable but are continuously adapting to changing environments. They can be characterized as a multiplex, comprised of many domains, many players, and a complex overlay of interactions and relationships combining them.<fnref n="368" /> Organizational leaders are increasingly challenged in coping with uncertainty and unpredictability. They are challenged by external expectations to ‘be accountable’ but also to ‘be performance oriented.’ They need governance that finds a balance between those two objectives but in organizations as a multiplex in flux that is not an easy endeavour.

This complexity has led organizational leaders to a governance strategy to not only use information technology for realizing performance (for which it is exceptionally well equipped) but also for realizing accountability, trying to translate *post factum* evaluations into *pre factum* definitions of rules and procedures to ensure compliance.<fnref n="369" /> This ICT governance strategy may work but most often results in inflexible and static systems. Employees experience these systems as increasingly contradictory with their routines, leading to unpredictable (mostly (pro-social) deviant) behaviour (as retrospective inscribing), harming accountability and performance. This strategy is based on the assumption that information technology systems of high-quality capture information of high-quality. That assumption proved, in the end, to be wrong.<fnref n="370" /> As I emphasized before: organizations do not necessarily need *information systems*, but they do need relevant *information* of good quality. *Information* governance is, thus, a ‘must.’ It is the ‘operating system’ for infor-

<footnote n="368">³⁶⁸ Falconer (2002), 31–34.</footnote>

<footnote n="369">³⁶⁹ Heidelberg (2017), pp. 1383–1387.</footnote>

<footnote n="370">³⁷⁰ Before: pp. 23–24.</footnote>
mation management (including rules, decision-making rights, secu-
rity and risk parameters), and realizes the governing of interactions
that define the coordination and control environment for the valu-
ation, creation, collection, analysis, distribution, storage, retention,
disposal, preservation, and use of information. Organizational lead-
ers need such an ‘operating system’ as part of organizational gov-
ernance to reach both of the organization’s objectives, without se-
verely damaging (one of) them.

Information governance is the part of organizational governance that directly influences the operational tools, mechanisms, and behaviours that concern information and information management. Enterprise information management ‘takes care’ of all information in the organization and follows the direction of information governance to assist both objectives of organizational governance: performance and accountability. Its effectivity has been negatively influenced by the neglect of organizational leaders, the deviant information behaviour of employees (as a result of neglect), and the lack of a theoretical foundation. <fnref n="371" /> For reaching the objectives of performance and accountability, enterprise information management is (at least) in need of a theoretical foundation that is attuned to the workings of an organization, the processing and archiving of ‘trusted’ information, and the recognition that ‘trusted’ information is necessary for both performance and for compliance and accountability processes. I developed the framework of the ‘Archive-as-Is’ for such a necessity. The framework can be used by organizational and information governance to define the coordination and control environment for the information value chain and to create an eval-

<footnote n="371">³⁷¹ About neglect: see pp. 20–21 here before; about deviant information be-
haviour: Van Bussel (2020), pp. 59–61; about lack of a theoretical founda-
tion: Van Bussel (2017), pp. 19–23.</footnote>
uation environment for ethical behaviour. Especially this last one is
a crucial component: as has been shown before, behaviour of man-
agers and other employees needs to be addressed when balancing
both objectives of organizational governance.

Organizational and information governance need a strategic ap-
proach to handle the manifestations of accountability (and perfor-
mance!) that have been described before. A strategic approach is also
needed because some manifestations have accountors that try to
change the phases of temporality that are part of an accountability
relationship: [1] assessing of information, [2] discussion, question-
ing, and answering, and [3] the definition of consequences, punish-
ments and/or rewards. Some of these accountors abuse their power
to offer an organization only the possibility to submit a report and
face consequences. <fnref n="372" /> This may be called accountability but seems
to be more about control than about accountability. It cannot al-
ways be avoided but an organization’s governance structure should
be prepared for such occasions.

As Raphael Zumofen observed, in accountability research the
accountee has always been the centre of interest. <fnref n="373" /> That is not in-
correct, because an accountee has to ‘be accountable.’ Accountees
perceive such a view as incorrect. From their point of view, the ex-
pectations and (potential) demands of the accountor are the centre
of interest. An accountee (in this case: an organization) has to pro-
vide a response, either reactive or proactive, to every (potential) de-
mand from an accountor, for every accountability manifestation it
is confronted with. From an organization’s point of view, the re-
sponse to the expectations and demands of an accountor is maybe
the most important part of the accountability relationship. Expec-

<footnote n="372">³⁷² Following Zumofen (2015), pp. 6–8.</footnote>

<footnote n="373">³⁷³ Zumofen (2015), p. 7.</footnote>
tations and demands are based on [1] explicit (or *de jure*) standards, codified in law, regulations, or contractual obligations, and [2] implicit (or *de facto*) standards, general notions of acceptable action and behaviour as defined by societal values, beliefs, and assumptions.<fnref n="374" /> Handling accountability for those expectations and demands contains at least two dimensions: [1] performance standards, explicit or implicit, generated by the organizational environment, embedded in and directed by organizational (and information) governance; and [2] a response, reactive or proactive, from the organization on the expected performance standards for the manifestation of organizational accountability it has to account for, including discussions about how the organization perceives itself to ‘be accountable’, how it perceives itself to be compliant to the required standards, and the evidence it presents to demonstrate this compliance.

Such a response is part of a strategic approach to accountability in which the organization itself tries to proactively engage with and plan for external expectations and demands within its organizational governance structure.<fnref n="375" /> This book emphasized that integrity-based ethics management and (organizational) behaviour are important for realizing the objectives of organizational governance. It is impossible to realize a strategic approach to accountability without defining a strategic approach to ethical behaviour.

My strategic approach to accountability is based on the research of Kevin Kearns and Raphael Zumofen but is much more detailed. The approaches op Kearns and Zumofen concentrate solely on accountability and ignore behaviour. My approach consists of three components: [1] a strategic approach to *ethical behaviour* as it is (1)

<footnote n="374">³⁷⁴ K.P. Kearns (1994). ‘The strategic management of accountability in non-profit organizations. An analytical framework’, *Public Administration Review*, Vol. 54, No. 2, pp. 185–192, p. 187.</footnote>

<footnote n="375">³⁷⁵ Kearns (1994), pp. 87–88.</footnote>
crucial for accountability as well as performance, (2) essential to peer accountability, the only manifestation of organizational accountability that influences success or failure of all other manifestations, that is completely informal, and based on peer evaluation of ethics and behaviour, and (3) neglected by organizational leaders although there are measurements that point out that ethical behaviour of managers and employees is creating (financial) problems; [2] a strategic approach to accountability, positioning accountability as an objective that has to be carefully planned and prioritized; and [3] external checks on the internal procedures of both approaches as an extra assurance for outside accountors that the organization is doing everything it can to 'be accountable' on strategic, tactical, and operational organizational levels. The separate steps in these three components will be introduced individually in order to obtain a practical guideline that could be used in each and every organization to realize a high-level strategic approach in organizational governance for ethical behaviour and accountability.

First, the strategic approach to ethical behaviour is divided in ten separate steps. Its objective is stimulating and evaluating behaviour that is in accordance with organizational values, a code of expected behaviour, and guidelines for integrity and compliance. These ten steps are presented in Figure 13.

<table><caption>Figure 13. Strategic approach to ethical behaviour</caption><tr><td>1. Identification or organizational values</td><td>Determining what the organization is about, which values it adheres to (like: honesty, fairness, integrity, trustworthiness, respect) and which values it wants to present to its environment</td></tr><tr><td>2. Identification of the ethical implications of organizational values</td><td></td></tr></table>
Determining the ethical consequences of those values, especially for the behaviour of employees

### 3. Identification of the expected ethical behaviour

Determining the expected ethical behaviour for employees in different business processes, (management) roles, and activities, based on the ethical implications of organizational values

### 4. Definition of a code of expected ethical behaviour

Capturing the specifics of expected ethical behaviour in a code as a requirement for employee behaviour, defining acceptance boundaries for (pro-social and/or deviant) behaviour

### 5. Definition of guidelines for integrity and compliance

Capturing guidelines for integrity and compliance, based on the code of expected ethical behaviour, defining boundaries for (pro-social and/or deviant) behaviour

### 6. Communication of the code (4) and guidelines (5)

Communication of the code of expected ethical behaviour and the guidelines for integrity and compliance to all managers and employees, using formal and informal communication channels. All managers need to align behaviour in teams or work groups with the code and guidelines and communicate and discuss this with their team or work group members

### 7. Training of employees according to code (4) and guidelines (5)

Training of all managers and employees in the application of the code of expected ethical behaviour and the guidelines for integrity and compliance in behaviour. This training will be part of socialization processes in the organization. All managers and employees need to participate periodically in training, based on teams or peer groups

### 8. Training of assessors in assessing the code (4) and guidelines (5) in managers and other employee assessments
<table><tr><td>Training assessors in evaluating the code of expected ethical behaviour and the guidelines for integrity and compliance in all employee assessments, especially in the evaluation mechanisms used, in the recognition of deviant behaviour, and in the possibilities for formal and informal punishments and rewards in accordance with code and guidelines</td></tr><tr><td>8. Periodical evaluation of the behaviour of managers and other employees for compliance to the code (4) and guidelines (5), including punishments or rewards.</td></tr><tr><td>Evaluating the behaviour of both managers and employees against the code of expected ethical behaviour and the guidelines for integrity and compliance, and capturing evaluations in assessment reports</td></tr><tr><td>9. Evaluation of the outcomes: analysis of the results of the assessments and definition of the learnings.</td></tr><tr><td>Evaluating assessment outcomes and definition of learnings (and improvements)</td></tr><tr><td>10. Application of the learnings in the approach to ethical behaviour</td></tr><tr><td>Application and implementation improvements into the approach.</td></tr></table>

Second, a strategic approach to accountability is divided in twelve separate steps. Its objective is defining responses to accountants and preparing to be accountable for all manifestations of organizational accountability. These twelve steps are presented in Figure 14.

<table><caption>Figure 14. Strategic approach to accountability</caption><tr><td>1. Identification of the manifestations of organizational accountability, including their source, power, and spatial direction.</td></tr></table>
Determining accountability manifestations that influence the organization and their source, power, and spatial direction, to gain an overview of existing and potential accountability relationships to allow for prioritization of manifestations and responses

## 2. Prioritization of manifestations or organizational accountability

Determining the relative importance of the separate manifestations for the organization to define urgency and to plan accountability activities accordingly

## 3. Identification of the ethics management needed

Determining the ethics management (compliance, integrity, or both) needed for each separate manifestation

## 4. Identification of the accountors

Determining all accountors that the organization has or will have to deal with in order to be able to respond to all demands, potential demands, or obligations

## 5. Identification of the expectations and demands of identified accountors

Determining the various expectations and demands of the different accountors, based on type (known or anticipated) and degree of obligation (de jure or de facto)

## 6. Classification of accountors and expectations and demands

Classifying accountors according to their demands to gather some accountors under the same category of demands, to potentially spare resources when responding to them, and to identify similar information needed

## 7. Evaluation of the accountability environment

Evaluating [1] potential changes in the used legal or regulatory standards, [2] potential changes in the informal or implicit standards, [3] the opinion leaders defining these standards, [4] the tactics or strategies available to help ensure the organization's accountability, and [5] the experiences of comparable organizations, to select the right tools to define an adequate strategic response
<table><tr><td>8. Implementing internal accountability structures based on Steps 1 to 7</td><td>Implementing the internal accountability structures that allow for documenting policies, decisions, products, actions and transactions, based on the prioritization of accountability manifestations and identification of needed ethics management. Internal accountability relationships need to be defined and an internal auditing structure has to be implemented. This internal auditing structure need to emphasize evidence, as this can be used in response presentations</td></tr><tr><td>9. Selection of response presentation</td><td>Determining and selecting the evidence the organization will need in order to fulfil the requirements of each category of accountants</td></tr><tr><td>10. Definition of the response</td><td>Determining to be reactive or proactive, or formal or informal, determined by the perception how to present and convey the organizations' message</td></tr><tr><td>11. Evaluation of the outcomes: analysis of the results of the accountant assessments and definition of the learnings</td><td>Evaluating accountant assessment outcomes and definition of learnings (and improvements)</td></tr><tr><td>12. Application of the learnings in the approach to accountability</td><td>Application and implementation improvements into the approach</td></tr></table>

Third, *external audits on the internal procedures of both approaches* as an extra assurance for outside accountors that the organization is doing everything it can to ‘be accountable’ on strategic, tactical, and operational organizational levels. This phase consists of four steps. These steps are presented in Figure 15.
<table><caption>Figure 15. External audits on the internal procedures of both approaches</caption><thead><tr><th></th><th></th></tr></thead><tbody><tr><td>1. External audit of the behavioural assessment process</td><td>External audit of the behavioural assessment process implemented by the organization to ensure that managers and employees behave within the boundaries defined within the code of expected ethical behaviour and the guidelines for integrity and compliance</td></tr><tr><td>2. External audit of the accountability process</td><td>External audit of the accountability process implemented by the organization (as well as the internal audit structure) to ensure a strategic response to the various accountors of the manifestations of organizational accountability</td></tr><tr><td>3. Evaluation of the outcomes: analysis of the results of the audits and definition of the learnings</td><td>Evaluating audit outcomes and definition of learnings (and improvements)</td></tr><tr><td>4. Application of the learnings in the approaches to behaviour and accountability</td><td>Application and implementation improvements into the approaches</td></tr></tbody></table>

A strategic approach to accountability is not new. An approach that combines accountability, behavioural assessments, and external audits on the internal approaches most certainly is. An approach like that is needed in the multiplex an organization is nowadays. Even with such an approach, the complexity of the environment and the quickly changing parameters do not guarantee success. That is the reason a learning cycle has been integrated into the approach.
Implementing learnings and continuous improvements allow for quick adaptation to new circumstances which fully fits the trend of strategic flexibility.<fnref n="376" /> Enterprise information management helps in taking care of organizational information, directed by that part of organizational governance that concerns information.

Organizational governance, my strategic approaches to behav-
iour and accountability, and the theoretical foundation of enterprise
information management in my framework of the ‘Archive-as-Is’
prepare organizations to ‘be accountable’ by tackling that problem
on different levels: behaviour, accountability responses, and infor-
mation (management). Together, they create a complex model,
which is difficult to realize but will have positive results when used.

Two remarks to end this book.

Issues of accountability emerge largely from employee uncer-
tainty, influenced by an unstable organization that is continuously
in flux, and susceptible to changes in its environment. Strategic flex-
ibility and responsiveness are traits that organizations should de-
velop, together with flexible control based on employee integrity.
Accountability favours the organization that is ‘aware, prepared, re-
sponsive, and open — and most firms are entrenched, hopeful, reac-
tive, and defensive.’ <fnref n="377" /> Organizational leadership should direct or-
ganizational governance in ‘opening up’ their organizations and
continuously implement their organizational values in employee
behaviour.

Organizational strategy needs to be viewed more as a function
of the organization than as an artificial construct that has effect on
it. Traditionally, strategy formulation and implementation are

<footnote n="376">³⁷⁶ D. Brozovic (2016). ‘Strategic flexibility. A review of the literature’, *International Journal of Management Reviews*, Vol. 20, No. 1, pp. 3–31.</footnote>

<footnote n="377">³⁷⁷ Falconer (2002), p. 35.</footnote>
speculatively directed with one-, three-, and/or five-year scales. Strategy should be viewed as a continuous phenomenon, 'part of a symbiotic, self-organizing system that involves constant interplay with the decisions taken by and the ongoing operation' of the organization.<fnref n="378" /> Just like operational flexibility, strategic flexibility is essential for creating an organizational governance where accountability can quickly be brought to the attention of organizational leaders to flexibly adapt organizational strategies for behaviour and accountability and to respond to them. The described strategic approach above will be adapted many times. The necessity for a flexible strategy for accountability, however, will be just as urgent now as it will be in the future.

<footnote n="378">³⁷⁸ Falconer (2002), p. 36.</footnote>
This page is intentionally left blank
PAPERS ON INFORMATION AND ARCHIVAL STUDIES

ISSN 2667-2804

I.

G.J. van Bussel (2020). *A Sound of Silence. Organizational Behaviour and Enterprise Information Management*. Papers on Information and Archival Studies, I, Van Bussel Document Services, Helmond. xii + 109 pp. ISBN/EAN 978-90-831078-0-6.

II.

G.J. van Bussel (2021). *An Accountability Puzzle. Organizations, Organizational Governance and Accountability*. Papers on Information and Archival Studies, II, Van Bussel Document Services, Helmond, x + 168 pp. ISBN/EAN 978-90-831078-1-3.
This page is intentionally left blank
<figure><img src="image_3.png" /></figure>

VAN BUSSEL DOCUMENT SERVICES
HELMOND
THE NETHERLANDS