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# An Accountability Puzzle

Geert-Jan van Bussel

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Geert-Jan van Bussel. An Accountability Puzzle: Organizations, Organizational Governance and Accountability. Dr. G.J. van Bussel., II, 2021, Papers on Information and Archival Studies, Dr. G.J. van Bussel, 978-90-831078-1-3. hal-03452609

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Papers on Information and Archival Studies II

*An Accountability Puzzle*

Organizations, Organizational Governance
and Accountability

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DR. GEERT-JAN VAN BUSSEL
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# An Accountability Puzzle
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Papers on
Information and Archival Studies

II

# An Accountability Puzzle

Organizations,
Organizational Governance,
and Accountability
Van Bussel Document Services
5704 NR 421 Helmond
The Netherlands
www.vbds.nl

The Papers on Information and Archival Studies are published electronically. The copyright of the papers is held by the author or authors of each paper. Papers may not be reproduced without permission of the copyright holder. Short sections of text, not to exceed two paragraphs, may be quoted without explicit permission provided that full credit is given to the source.

To cite this paper:

Bussel, G.J. van (2021). *An Accountability Puzzle*. *Organizations, Organizational Governance, and Accountability*. Papers on Information and Archival Studies, II, Van Bussel Document Services: Helmond.

© G.J. van Bussel 2021

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VAN BUSSEL
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The author

Geert-Jan van Bussel (1960) is an independent consultant, researcher, and auditor, specialized in information governance, digital archiving, and compliance. He is a leading auditor of records management and archiving standards (ISO 15489, ISO 16175, ISO 23081 and ISO 16363). As a strategic consultant he is asked for assistance by many (international) business organizations and government agencies. He is senior lecturer and researcher at the Amsterdam University of Applied Sciences and Assistant Professor at the University of Amsterdam. He is one of the leading archival scholars in the Netherlands and is a visiting lecturer at several universities in Europe. He was member and president of the Special Commission for the Archives (1998–2002; 2009–2011), a commission of the Council of Culture, the most important advisory body on culture for the Dutch government. He is a (keynote) speaker on many (international) seminars and conferences, mostly on the effects and influence of information processing and information management on people’s work. He published more than hundred papers and five books on business processes, governance, auditing, compliance and digital archiving.
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# CONTENTS

*

1 **Short-Termism, research subject, and structure** 1

Short-Termism 2

Research subject 8

Structure of this book 9

2 **Governance and Organizations** 11

Organizational governance: governing interactions and information 12

Information Governance 21

*Key driver* 21

*ICT governance* 25

*Governing information* 27

*Directing information management* 30

Aligning performance and accountability 31

Rules and routines 35

The ethics of accountable governance 45

Collective or individual? 53

Finding equilibria 56

3 **The Accountability Concept** 59

A few introductory words 60

A word and a concept 61

Accountability: a short history 65
<table><tr><td>Assumptions and barriers</td><td>70</td></tr><tr><td>Accountability: the concept</td><td>78</td></tr><tr><td style="padding-left: 2em;">Janus-faced</td><td>78</td></tr><tr><td style="padding-left: 2em;">Different Meanings</td><td>81</td></tr><tr><td style="padding-left: 2em;">Accountability as a virtue or as a mechanism</td><td>83</td></tr><tr><td style="padding-left: 2em;">Accountability's core structure</td><td>88</td></tr></table>

4. **Organizational Accountability and its Manifestations** 91

<table><tr><td>Source, power, and space</td><td>92</td></tr><tr><td>The many manifestations of organizational Accountability</td><td>98</td></tr><tr><td style="padding-left: 2em;">'Many eyes' and a puzzle.</td><td>98</td></tr><tr><td style="padding-left: 2em;">Organizational accountability: a framework's introduction</td><td>101</td></tr><tr><td style="padding-left: 2em;">Organizational accountability: a framework</td><td>108</td></tr><tr><td style="padding-left: 2em;">The economic domain</td><td>110</td></tr><tr><td style="padding-left: 2em;">The governing domain</td><td>116</td></tr><tr><td style="padding-left: 2em;">The social network domain</td><td>134</td></tr><tr><td style="padding-left: 2em;">The societal domain</td><td>139</td></tr><tr><td style="padding-left: 2em;">A framework: some conclusions</td><td>146</td></tr></table>

6. **A strategic approach** 153
1

SHORT-TERMISM,
RESEARCH SUBJECT AND STRUCTURE

*
In July 2008, the crisis in the United States impacted financial institutions all over the world. In the third quarter of that year, the crisis intensified with a number of corporate collapses and a loss of confidence that hit financial institutions worldwide. Several banks failed, in the United States as well as in Europe, while others needed government recapitalization towards the end of 2008. As the crisis unfolded, worldwide forty-five per cent of the existing wealth was destroyed. <fnref n="1" /> The crisis (a ‘Great Recession’) was the most severe

<footnote>* This book discusses the background for the framework of the Archive-as-Is' (2017): the organizational neglect in organizational governance of the business value of information, and of enterprise information management, the organizational function and systems that manage information during its life cycle, from creation to preservation or disposal. Organizational leaders neglect the management of information while they, at the same time, espouse its importance for their organizations. For the model of the Archive-as-Is: G.J. van Bussel (2017), 'The theoretical framework of the 'Archive-as-Is'. An organization oriented view on archives. Part I. Setting the stage: enterprise information management and archival theories. Part II. An exploration of the 'Archive-as-Is' framework,' F. Smit, A. Glaudemans, and R. Jonker (eds.), *Archives in Liquid Times*, SAP, 's-Gravenhage, pp. 16-41, pp. 42-71. Why enterprise information management cannot be neglected: 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. Online source, retrieved November 19, 2021, from: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3732196.</footnote>

<footnote n="1">¹ M. Pirson, and S. Turnbull (2011). 'Corporate governance, risk management, and the financial crisis. An information processing view', *Corporate Governance. An International Review*, Vol. 19, No. 5, pp. 459-470, p. 459.</footnote>
global recession since the 1930s and was followed by the European
debt crisis (starting with a deficit in Greece in late 2009, and the
Icelandic financial crisis of 2008–2011). <fnref n="2" /> There were serious failures
in risk management by governments, organizational boards, and fi-
nancial institutions. These failures were partly caused by an unwa-
vering belief in risk models that were never tested in a crisis. <fnref n="3" />

Nassim Taleb identified five forces: (1) an increase in hidden
risks of low probability events; (2) asymmetric and flawed incen-
tives that favoured risk hiding; (3) an increased promotion of meth-
ods to hide risks; (4) an increase of low probability economic events;
and (5) growing misunderstanding of the risks those events entail. <fnref n="4" />
Many causes are said to be responsible for this crisis, like fraud,
greed, incompetence, and folly by all actors on the marketplace. <fnref n="5" />
Mark Stein added, based on psychoanalysis and its application to

<footnote n="2">² Recession: P. Temin (2010). ‘The Great Recession and the Great Depression’, *Daedalus*, Vol. 139, No. 4, pp. 115–124. Online source, retrieved on November 19, 2021 from: https://www.jstor.org/stable/25790431. European debt crisis: M. Copelovitch, J. Frieden, and S. Walter (2016). ‘The political economy of the Euro crisis’, *Comparative Political Studies*, Vol. 49, No. 7, pp. 811–840.</footnote>

<footnote n="3">³ S. Shojai, and G. Feiger (2010). ‘Economists’ hubris. The case of risk management’, *Journal of Financial Transformation*, Vol. 28, pp. 25–35, pp. 25–26. Online source, retrieved on November 19, 2021, from: https://ideas.repec.org/a/ris/jofitr/1408.html.</footnote>

<footnote n="4">⁴ N.N. Taleb (2010). ‘Why did the crisis of 2008 happen?’ (third version). Online source, retrieved on November 19, 2021 from: https://www.fooledbyrandomness.com/crisis.pdf. Taleb identifies the crisis of 2008 as a ‘Black Swan’: an unpredictable event that is (extremely) beyond what is a normally expected situation and that has potentially severe consequences. See: N.M. Taleb (2010). *The Black Swan. The Impact of the Highly Improbable*, Random House Trade, New York (second edition).</footnote>

<footnote n="5">⁵ Pirson and Turnbull (2011), p. 459.</footnote>
social and organizational dynamics, the notion of a ‘manic culture’, comprised of four components: denial (of one’s vulnerabilities and the encountered problems), omnipotence (feelings of invulnerability), triumphalism (the need to be victorious, and to demonstrate one’s superiority over others), and over-activity (to dispel any concerns about their risks and vulnerabilities.) <fnref n="6" /> As a result of such a ‘manic culture’, the context of the (organizational) behaviour that led to this ‘Great Recession’ can be more easily explained. One of the most eye-catching characteristics of the financial crisis was short-termism or myopia, an excessive focus of boards and senior management on short-term results and a denial of long-term value creation. This can be associated with the components of a ‘manic culture’ as described by Stein. Natalie Mizik has described short-termism as a type of (systemic) management behaviour that ‘overemphasize[s] strategies with immediate pay-offs at the expense of strategies with superior but more distant pay-offs’. Mizik calls this ‘myopic management’, or ‘manipulation of real activities’. <fnref n="7" /> It affects economic profits directly because it alters operational practices and business processes (for instance, cutting marketing and innovation efforts to reach earning targets.) Non-financial companies sought to increase their stock price and/or profits by inflating earnings at the expense of their long-term value and health. This included under-investing in long-term assets or taking on excessive risk to maximize short-term earnings. <fnref n="8" /> For financial companies,

<footnote n="6">⁶ M. Stein (2011). ‘A culture of mania. A psychoanalytic view of the incubation of the 2008 credit crisis’, *Organization*, Vol. 18, No. 2, pp. 173–186.</footnote>

<footnote n="7">⁷ N. Mizik (2010) ‘The theory and practice of myopic management’, *Journal of Marketing Research*, Vol. 47, No. 4, pp. 594–611, p. 594.</footnote>

<footnote n="8">⁸ S. Roychowdhury (2006). ‘Earnings management through real activities manipulation’, *Journal of Accounting and Economics*, Vol. 42, No. 3, pp. 335–370. See also: L.L. Dallas (2012). ‘Short-termism, the financial crisis,</footnote>
short-termism involved investing in assets with hidden risks, taking
on excessive debt to bolster short-term profits or portfolio returns,
and using strategies that ignored corporate value, resulting in losses.
It included using voting rights to force firms to provide direct pay-
back through payouts, stock repurchases, or selling off assets or di-
visions. <fnref n="9" /> Cultures within financial firms focused on end results, on
competition among traders, on success attributed to profit-making
skills, on extreme disparities in individual rewards, and an environ-
ment that boosted self-interest. <fnref n="10" /> It allowed for employee behav-
iour that was inherently unethical, and stimulated individuals to
seek their own short-term gains at the expense of their firms. The
changes in organizational forms of many investment banks in the
1990s (from partnerships to public corporations) contributed to this
transformation in organizational behaviour. From risking the capi-
tal of their partners, investment banks became public corporations
with shareholders that would bear the risk of losses. Together with
deregulation, globalization, and high incentives, this led to the
spread of a risk-taking culture in the financial industry. <fnref n="11" /> Fund

<footnote>and corporate governance’, *Journal of Corporation Law*, Vol 37, No. 2, pp. 264–363, pp. 267–268, 281–310.</footnote>

<footnote n="9">⁹ Mizik (2010), p. 596; Dallas (2012), pp. 268, 307–309.</footnote>

<footnote n="10">¹⁰ R.G. Rajan (2005). ‘Has financial development made the world riskier?’, *The Greenspan era. Lessons for the Future. A Symposium Sponsored by the Federal Reserve Bank of Kansas City*, Jackson Hole, Wyoming, August 25–27, Federal Reserve Bank, Kansas City, pp. 313–369, esp. pp. 334–341. The hostile reception of this analysis (‘largely misguided’) (proven correct two years later) illustrated the existing myopia. It confirmed the existence of a ‘manic culture’ in the feelings of denial, omnipotence, and triumphalism.</footnote>

<footnote n="11">¹¹ M. Adelson (2020). ‘The mortgage meltdown and the failure of investor protection’, *The Journal of Structured Finance*, Vol. 26, No. 1, pp. 63–86, pp. 78–79. Also: K. Dowd (2009). ‘Moral hazard and the financial crisis’, *Cato Journal*, Vol. 29, pp. 141–166, pp. 142–145.</footnote>
managers and bankers were seduced by their own propaganda and believed that poor-quality loans could be transformed into high-quality investments. <fnref n="12" /> The cause for that belief was a ‘culture of greed’, induced by short-termism and organizational cultures in which supercharged remuneration systems promised riches in return for minimal personal risks. The organizational cultures in financial institutions induced behaviour that trampled moral values, temperance, and the ability to restrain the desire for success, wealth, or social recognition. Despite realizing what was happening, managers evaded difficult decisions that could jeopardize their career or remuneration. <fnref n="13" /> There was, to be expected in a ‘manic culture’, arrogance among bankers, economists, and governments, convinced their knowledge was superior, there was no reason to be accountable, or follow the law. They withheld, altered, fabricated, or destroyed information, misleading the public about worsening product performance. They showed more willingness to lie than to reorient their values. <fnref n="14" /> Weak internal controls did nothing to curb

<footnote n="12">¹² J. Tirole (2010). 'Lessons from the crisis', M. Dewatripont, J.-C. Rochet, and J. Tirole. *Balancing the Banks. Global Lessons from the Financial Crisis*, Princeton University Press, Princeton (NJ), chapter 2, pp. 10–77, especially pp. 45–47.</footnote>

<footnote n="13">¹³ A. Argandona (2012). *Three Ethical Dimensions of the Financial Crisis*. Working Paper-WP-944, IESE Business School, University of Navarra, Madrid, pp. 3–4. Online source, retrieved on November 19, 2021, from: https://ssrn.com/abstract=2079578. A ‘culture of greed’ is derived from: D. Whitby (1996). ‘Barings. A culture of greed?’, *Journal of Financial Crime*, Vol. 3, No. 4, pp. 377–381.</footnote>

<footnote n="14">¹⁴ A. Szyszka (2010). ‘Behavioral anatomy of the financial crisis’, *Journal of CENTRUM Cathedra*, Vol. 3, No. 2, pp. 121–135. Online source, retrieved on November 19, 2021, from https://ssrn.com/abstract=1806037. Also: Argandona (2012), p. 3, and: D. Colander, M. Goldberg, A. Haas, K. Juselius, A. Kirman, T. Lux, and B. Sloth (2009). ‘The financial crisis and the</footnote>
unethical behaviour. Supervisory systems were flawed and did not correct the problems of weak supervisory independence, flawed governance and accountability, wrong incentives provided by governments, lack of audacity to be intrusive, and a general lack of skills. They all disregarded the needs of the public. <fnref n="15" /> Just as problematic was that, as Bernard Black stated in 1990, long before this financial crisis hit the economic system, most organizations recognized that, appearances notwithstanding, formal laws were ‘trivial’, that they do not prevent unethical cultures, and that ignoring rules without serious legal consequences was quite normal. <fnref n="16" /> Short-termism, in short, promoted, without checks and balances, behaviour that was addicted to ‘the erroneous and dangerous idea that the stock market is a place to get rich quickly’, with the financial crisis as its consequence. <fnref n="17" />

<footnote>systemic failure of the economics profession', *Critical Review*, Vol. 21, No. 2-3, pp. 249-267, especially pp. 262-263.</footnote>

<footnote n="15">¹⁵ Pirson and Turnbull (2011); Shohaj and Feiger (2010); Stein (2011); Dallas (2012), and D. Masciandaro, R. Vega Pansini, and M. Quintyn (2011). *The Economic Crisis. Did Financial Supervision Matter?*. IMF Working Paper No. 11/261, IMF, Washington DC. Online source, retrieved on November 19, 2021, from: https://ssrn.com/abstract=1961908.</footnote>

<footnote n="16">¹⁶ B. Black (1990). 'Is corporate law trivial? A political and economic analysis', *Northwestern University Law Review*, Vol. 84, No. 2, pp. 542-597, p. 547. Black states (pp. 547-548) that mandatory rules are trivial in one of four ways: they mimic best practices and professional codes and will be adopted anyways; they can be avoided by planning in advance; they matter temporarily and will be changed; or they are unimportant (in their consequences). Black states that it is near impossible to prove their nontriviality.</footnote>

<footnote n="17">¹⁷ M. Tonello (2006). *Revisiting Stock Market Short-Termism*, The Conference Board Research Report No. R-1386-06-RR, The Conference Board, New York, p. 8. Online source, retrieved on November 19, 2021, from: https://ssrn.com/abstract=938466.</footnote>
When things go wrong, implementation of more stringent regulations follows to curtail such unethical business behaviour. Penalties are increased for destroying, altering, or fabricating information, for defrauding shareholders, and to increase standards for both organizational governance and accountability. Institutionalizing stricter rules and regulations is seen as a solution for such a ‘wrong’. In theory, such regulation makes organizational executives, managers, and other employees more aware of their accountability for their day-to-day policies, decisions, products, actions, and transactions. Governments believe that such a strategy will instil fear of punishment, that it will stimulate stronger governance, more ethical behaviour, and increasing organizational accountability. <fnref n="18" /> Such a belief emerges from a governance and accountability model that is prevalent in current government bureaucracies, and that belief may be, as Black emphasized, incorrect. <fnref n="19" />

In this book, the subject of research is the relationship between organizational governance and accountability, the concept that describes that, when things go wrong, ‘society’ wants someone (an individual, a group of individuals, or an organization) to be accountable (and, if possible) ‘punished’ for what has happened. Defining stricter rules after a crisis is an impulse to reassure ‘society’ that ‘we’ (the governments, professional associations, or supervisors) have done everything possible to avoid such problems in the future. The

<footnote n="18">¹⁸ The International Bar Association’s Task Force on the Financial Crisis (2010). *A Survey of Current Regulatory Trends*, IBA, London.</footnote>

<footnote n="19">¹⁹ Black (1990), pp. 547 and 593.</footnote>
regulations implemented as a result of the ethical (behavioural) fail-
ures during the financial crisis (or, as another example, the fraudu-
lent behaviours of, for instance, Enron and WorldCom in the years
before that crisis) provide examples of this strategy.

STRUCTURE OF THIS BOOK

********

This book is structured as follows:

1. This introduction in which the governance and accountability failures in organizations during (and since) the financial crisis is introduced, resulting from short termism, followed by a description of this book, and its structure;

2. An analysis of organizational governance, its relationship to ac-
countability, rules and routines, employee behaviour, and busi-
ness ethics as well as information governance and its relationship
with enterprise information management;

3. A description of the core concept of this study, accountability, the existing assumptions in rules and regulations and their problems, its early history, and its key features;

4. An analysis of organizational accountability, in which I will dis-
cuss its dimensions and its multiple manifestations and come to
some conclusions;

5. A proposal for a strategic approach to accountability in organi-
zational governance, consisting of three components: a strategic
approach to ethical behaviour, a strategic approach to accounta-
bility, and an external evaluation of both approaches.
1

GOVERNANCE AND ORGANIZATIONS

*
ORGANIZATIONAL GOVERNANCE: GOVERNING
INTERACTIONS AND INFORMATION

********

Organizational leaders need to find answers to assuage society’s expectations for governance and accountability. That is not easy because of the scrutiny of their behaviour by governments, the public, professional associations, communities, and interest groups. One of the tasks of organizational leaders is to realize an accountability function in the governing structure(s) of their organization to translate these external expectations to internal controls. They need to implement accountability mechanisms that co-exist with mechanisms that enhance organizational performance. A review of the literature from 1990 onwards reveals that accountability (better: this internal accountability function) has continuously been defined as an aspect of governance, just like transparency, performance, effectiveness, structure, and power. 20 Studying accountability, hence, should be done in a context of governing and governance.

Thomas Clarke already stated that the theory of governance is
‘not robust or well-rooted.’ 21 There is a multiplicity of definitions
for the term ‘organizational governance.’ There are also different
governance approaches across different cultures. Barbara L’Huillier

<footnote n="20">20 L. Ruhanen, N. Scott, B. Ritchie, and A. Tkaczynski (2010). ‘Governance. A review and synthesis of the literature’, *Tourism Review*, Vol. 66, No. 4, pp. 4–16. See also: E.F. Pomeranz, and R.C. Stedman (2020). ‘Measuring good governance. Piloting an instrument for evaluating good governance principles’, *Journal of Environmental Policy and Planning*, Vol. 22, No. 3, pp. 428–440.</footnote>

<footnote n="21">21 T. Clarke (1998). ‘Research on corporate governance’, *Corporate Governance*, Vol. 6, No. 1, pp. 57–97, p. 62.</footnote>
asserts that, besides intentional acts of discourse, the variations in
the meaning of the term may relate to conflicts in (or between) phil-
osophical traditions and the theoretical schools based on those tra-
ditions. She recognizes six theoretical traditions in organizational
governance literature that influence its meaning and definition. Ac-
cording to L’Huillier, agency theory, stewardship theory, resource
dependency theory, managerial hegemony theory, stakeholder the-
ory, and multi-governance theory each convey a different meaning
when using the term ‘organizational governance.’<sup>22</sup> The most dom-
inant theory is the agency theory, which ‘has been the predominant
paradigm for understanding and explaining corporate governance
issues.’<sup>23</sup>

Organizational governance is, according to Jan Kooiman, ‘the
totality of interactions in providing direction, exercising control
and coordination, and allocating available resources within organi-
zations, based on an identifiable locus of authority and responsibil-
ity.’<sup>24</sup> It is the way in which organizational components are organ-

<footnote n="22"><sup>22</sup> B.M. L’Huillier (2014). ‘What does ‘corporate governance’ actually mean?’, *Corporate Governance*, Vol. 14, No. 3, pp. 300–319, p. 300, p. 304, pp. 304–311. Although mostly the term ‘corporate governance’ is used, I will use here, based on *ISO 26000: 2010 Social Responsibility*, ‘organizational governance’, a more generic designation, including both business and government organizations.</footnote>

<footnote n="23"><sup>23</sup> M.J. Rubach, and T.C. Sebora (2009). ‘Determinants of institutional investor activism. A test of the Ryan-Schneider model (2002)’, *Journal of Managerial Issues*, Vol. 21, No. 2, pp. 245–261, p. 245.</footnote>

<footnote n="24"><sup>24</sup> J. Kooiman (2003). *Governing as Governance*, SAGE, London, Part I, pp. 1–26, especially p. 4–5. See also: D. Fasenfest (2010). ‘Government, governing, and governance’, *Critical Sociology*. Vol. 36, No. 6, pp. 771–774; and B. Dallago (2002). ‘Corporate governance and governance paradigms’, *East–West Journal of Economics and Business*, Vol. 5, No. 2, pp. 173–196, p. 174. Organizational governance is defined in *ISO 26000: 2010*. *Social Re-</footnote>
ized, coordinated, allocated, and motivated to contribute to organi-
zational objectives and to adapt to environmental change. It encom-
passes all interactions concerning behavioural norms, processes,
standards, rules and routines, guiding operations, human relations,
business ethics, risk management, and compliance. ²⁵ It is, thus,
about the definition and allocation of the power to make decisions
and to control the organization.

However, that is not all there is. Governance also has to deal
both with motivations, incentives, and coordination of all the or-
ganization's (internal and external) relationships and interactions,
and with the process of change. This is not a simple matter, since it
is not clear what the boundaries of an organization are. Organiza-
tions and their environments are constantly in flux and organiza-
tional leaders are seriously challenged to cope with the accompany-
ing uncertainty and unpredictability. Organizations are complex,
open systems that appear outwardly stable, but are in fact con-
stantly in flux, shifting in response to changing environments. It is
a multiplex, comprised of many players, and an overlay of interac-
tions and relationships combining them. ²⁶ There are, first, many
different actors: shareholders, boards, creditors, subsidiaries, man-

sponsibility as: ‘a system by which an organization makes and implements
decisions in pursuit of its objectives’, based on: ‘the system by which com-
panies are directed and controlled’, in: *Report of the Commission on the Fi-
nancial Aspects of Corporate Governance* (Cadbury Report), Gee & Co.,
London, 1992, § 2.5. Online source, retrieved on November 19, 2021,
from: http://cadbury.cjbs.archios.info/report.

²⁵ S. Young, and V. Thyil (2008). ‘A holistic model of corporate governance. A new research framework’, *Corporate governance*, Vol. 8, no. 1, pp. 94–108.

²⁶ J. Falconer (2002). ‘Accountability in a complex world’, *Emergence. A Journal of Complexity Issues in Organizations and Management*, Vol. 4, No. 4, pp. 25–38, especially p. 32.
agers, employees, and many other stakeholders (suppliers, buyers, citizens, (local) communities and governments, etc.) All these actors have rights, preferences, and/or decision-making power. Each actor influences the performance and/or value of an organization. For each of these actors there may be different accountability requirements. Second, the boundaries of an organization are continuously adapting to changes in its environment, modifications in laws and regulations, and changes in markets or society. Changes like these will have consequences for all mentioned aspects of governance.<fnref n="27" />

The basic shape of the governance structure of organizations is provided by formal legal structures, addressing high-profile matters like allocation of decision-making rights and organizational control among directors, senior management, and other stakeholders (like, when applicable, shareholders.) However, those formal structures account only for a small part of how organizations actually work and how they adapt to their environment. The mass of what they do are processes of information flow, decision-making, decision-implementation, and decision-monitoring, intertwined with structures of organizational accountability. It is about how employees [1] obtain the information used in making, implementing, and monitoring the results of organizational decisions, including decisions concerning how to conduct business and decisions relating to its compliance with regulations; [2] cause that information to move up (or down) the organizational hierarchy from where it originates to the hierarchical level that has the knowledge to evaluate it; and [3]

<footnote n="27">²⁷ Dallago (2002), p. 175. See also: G.J. van Bussel (2018). ‘Archivos institucionales en el ‘Mundo 2.0’. El marco de actuación para el ‘Archive-as-Is’ [Archivo-como-es]’ (Organizational Archives in ‘World 2.0’. The framework for the ‘Archive-as-Is’), L.E. Casellas i Serra, and L. Hernandez-Olivera (eds.), *Espacios de Memoria. Estrategias y Discursos para Archivos Históricos*, ACAL, Salamanca, pp. 41-80, pp. 43-47.</footnote>
make, communicate, and monitor the implementation of decisions based on that information.<fnref n="28" />

For governance, enterprise information management is, thus, important, especially because information is an unusual good. It is both output and input, an end-product, and an instrument for creating other goods, decisions, and information. It is both expensive (creation) and inexpensive (use). Its value is subjective, since it may be of no use to one employee and of use to another. Information has value when it is given meaning in the context of an organization (work group, team, or place of work.) Information is an absolute necessity to improve performance.<fnref n="29" /> As such, the governance of information has to be a crucial part of organizational governance.

According to Kooiman, governance is an interaction concept.<fnref n="30" /> Employees interfere, collaborate, and are involved in many interactions in which information is a key asset. For solving organizational challenges, employees need guidelines to streamline these patterns of interactions, the use and exchange of information within these interactions, and how to use specific sensemaking contexts.<fnref n="31" /> This coordination and control environment needs governing of [1] interactions and the exchange and use of information, [2] the sensemak-

<footnote n="28">²⁸ R.J. Gilson (2018). 'From corporate law to corporate governance', J.N. Gordon and W.-G. Ringe (eds.), *The Oxford Handbook of Corporate Law and Governance*, Oxford University Press, Oxford, pp. 3-27, p. 7.</footnote>

<footnote n="29">²⁹ S. Rafaeli, and D.R. Raban (2003). 'Experimental investigation of the subjective value of information in trading', *Journal of the Association for Information Systems*, Vol. 4, No. 1, Article 5, pp. 119-139.</footnote>

<footnote n="30">³⁰ Kooiman (2003), p. 4, Chapter 2, pp. 11–25, Chapter 13, pp. 211–230.</footnote>

<footnote n="31">³¹ M.N. Kooper, R. Maes, and E. Roos Lindgreen (2011). 'On the governance of information. Introducing a new concept of governance to support the management of information', *International Journal of Information Management*, Vol. 31, No. 3, pp. 195-200, p. 197.</footnote>
ing contexts to understand and give meaning to interactions and in-
formation, and [3] the information management interactions that
safeguard the information value chain. <fnref n="32" /> Governing these interac-
tions and contexts is based on organizational authority layers. Each
layer is characterized by the power to initiate projects and direct
subordinates, exact obedience, ratify and approve actions in a pre-
determined area of competence, and monitor subordinates and re-
ward (or punish) them for their behaviour and performance. This
power defines and delineates both the coordination and control en-
vironment of interactions and sensemaking contexts and the con-
nected accountability framework. <fnref n="33" /> Power influences creation, use,
and exchange of information, the sensemaking contexts that give
meaning, and the information management interactions that safe-
guard the information value chain. It defines authority (and the ac-
countability framework), although its practical operationalization
and realization may be different.

Kooiman defined three modes of governance: hierarchical gov-
ernance, co-governance, and self-governance. <fnref n="34" /> Hierarchical gov-
ernance is the most dominant mode, but it is possible for organiza-
tions to implement adaptations of the other two modes of govern-
ance. Kooiman describes hierarchy as ‘the process in which leaders
control non-leaders.’ Although this is a generic description, it char-
acterizes the types of governing interactions with a ‘top-down’ ap-
proach. It is structured ‘vertical’, is formalized, with sanctions at-
tached, and based on (centralized) steering (for direction) and con-

<footnote n="32">³² About this chain: Van Bussel (2017), Part II, pp. 57–59.</footnote>

<footnote n="33">³³ P. Bolton, and M. Dewatripont (2013). ‘Authority in organizations. A survey’, R. Gibbons, and J. Roberts (eds.), *Handbook of Organizational Economics*, Princeton University Press, Princeton, pp. 342–372.</footnote>

<footnote n="34">³⁴ Kooiman (2003), Chapters 6–8, pp. 77–131.</footnote>
trol (for insurance).<fnref n="35" /> It is possible, using this bureaucratic mode of
governance, to embed (elements of) the other two governance
modes. Co-governance, according to Kooiman, is when interacting
parties have something ‘in common’ to pursue together, for in-
stance in networks. It includes forms of ‘horizontal’ governing:
communicating, collaborating or co-operating without a central or
dominating governing actor.<fnref n="36" /> Self-governance refers to the auton-
omous capacity of social entities to govern themselves, based on in-
formal agreements, self-applying rules, and semi-formalized codes
of conduct. It could be applied to local or regional divisions in mul-
tinational organizations, but also to professional associations. Har-
ald Torsteinsen treats hierarchal organizations as a set of continuous
variables, making it possible to analyse different degrees of bureau-
cracy and different mixes of variables. In his view, organization is
not possible without elements of hierarchical governance, which
does not mean that different modes of governance within bureau-
cracies are not possible. After all, networks, informal agreements,
self-applying rules, and codes of conduct can be (and are) found in
bureaucratic organizations.<fnref n="37" /> However, the mode of governance

<footnote n="35">³⁵ Kooiman (2003), p. 115–116, following: R.A. Dahl, and C.E. Lindblom (1953). *Politics, Economics, and Welfare*, Harper & Brothers, New York, p. 27.</footnote>

<footnote n="36">³⁶ K.G. Provan, and P. Kenis (2008). ‘Modes of network governance. Structure, management, and effectiveness’, *Journal of Public Administration Research and Theory*, Vol. 18, No. 2, pp. 229–252.</footnote>

<footnote n="37">³⁷ H. Torsteinsen (2012). ‘Why does post-bureaucracy lead to more formalisation?’, *Local Government Studies*, Vol. 38, No. 3, pp. 321–344. The post-bureaucratic organization is an ideal-type organization developed by C. Heckscher (1994). ‘Defining the post-bureaucratic type’, C. Heckscher, and A. Donnellon (eds.), *The Post-Bureaucratic Organization. New Perspectives on Organizational Change*, London, SAGE, pp. 14–62, pp. 25–28. This ideal-type is based on informal structures like [1] problem- and project-</footnote>
notwithstanding, information management proves to be important
in each of them, although its operationalization may differ.

The most important part of the organizational governance struc-
ture (its ‘dark matter’) are the interactions and relationships about
reporting, organizational structures, risk management, information
gathering, process performance, internal controls, internal monitor-
ing, and compliance. These are mostly ‘non-legally-dictated poli-
cies, practices, and procedures that do not appear in the corporate
statute or the corporation’s charter or bylaws’ but are still subject
to litigation. <fnref n="38" /> Organizations are expected to take their own policies
and procedures seriously and comply with them, otherwise non le-
gal governance processes morph into ‘legal’ ones. <fnref n="39" />

Governance (as an interaction concept) and enterprise informa-
tion management (as management of information in interactions)
are inextricably linked. And, as a consequence: the organizational
archive, all the information stored and retained in the context of its
generation and its use in the business processes of the organization
and in the ongoing and continuous interactions within and across
organizational boundaries, is indispensable, as its business value for

<footnote>driven interaction, [2] dialogue, consensus, and trust, [3] mission and gen-
eral principles, [4] looser organizational ties and borders, and [5] flexible
and more temporary, part-time memberships. It is only a theoretical con-
struct (as Heckscher (on p. 17) admits.) Torsteinsen states that informal
post-bureaucratic structures can be realized within a bureaucracy, with a
different mix of variables but still possessing the core-characteristics of the
bureaucratic organizational model.</footnote>

<footnote n="38"><sup>38</sup> Gilson (2018), p. 7. For ‘dark matter’: p. 8.</footnote>

<footnote n="39">³⁹ T.J. Fort, and M. Latini (2019). ‘The duty to establish, monitor, and enforce. How today’s corporate compliance standards provide a workable model to limit defamation and protect First Amendment freedoms’, *Notre Dame Journal of Law, Ethics and Public Policy*, Vol. 33, No. 1, pp. 35–68, p. 38.</footnote>
reaching performance and realizing accountability is undeniable. Nevertheless, while ‘organizational leaders accept that ‘information’ is a vital business asset, and continually reconfirm its espoused value for their organizations, in organizational life they do something different. They do not require the same discipline and rigour that applies for other business assets, like financial ones, for records and archives.’<fnref n="40" /> They do not manage information as a strategic asset.<fnref n="41" /> The effect: increased costs, customer dissatisfaction, less effective decision-making, problematic implementation of new technology, an organizational image at risk, and reduced ability to define and execute business strategies. It hurts employee morale and breeds mistrust. All phenomena organizational leaders try to prevent in (and with) their governance structures are neglected when it concerns information and information management.<fnref n="42" /> Joost Kampen and André Henken studied ‘organizational neglect’ and defined it as ‘the prolonged lack or absence of supervision and control.’ It is a gradual process with consequences that become visible only over time.<fnref n="43" /> In the end, it leads to information behaviour like hoarding,

<footnote n="40">⁴⁰ Van Bussel (2020), p. 59.</footnote>

<footnote n="41">⁴¹ N. Evans and J. Price (2018). ‘Death by a thousand cuts. Behaviour and attitudes that inhibit enterprise information asset management’, *Information Research*, Vol. 23, No. 1, paper 779. Online source, retrieved on November 19, 2021 from: http://InformationR.net/ir/23-1/paper779.html.</footnote>

<footnote n="42">⁴² Van Bussel (2020), p. 61, p. 64, and notes 170–171.</footnote>

<footnote n="43">⁴³ J. Kampen, and A. Henken (2018). ‘Organizational neglect. The toxic triangle of deficits’, *Organizational Dynamics*, Vol. 47, No. 4, pp. 241–249. Their definition (p. 243) is especially attuned to organizational development: ‘Neglect in the workplace is the prolonged lack or absence of supervision and control of organizational development, which has led to patterns of harmful interaction between management and staff.’ The core of this definition is the ‘lack or absence of supervision and control’, in our case of information and information management.</footnote>
hiding, fabricating, destroying, neglect of formal rules, and only es-
poused interest in changing information environments. Enterprise
information management proves to be extremely challenging for
organizational leaders. Reinitiating supervision and control for
something that is neglected is very difficult. It is, however, necessary
to embed information management into the same supervision and
control structures as other business assets. Governance of infor-
mation may be needed to arrange just that.

INFORMATION GOVERNANCE

********

Key driver

In most organizations a lean management model is accepted that
(ideally) distributes decision-making authority horizontally (i.e., to
those who do the work) and structures supervision and control ver-
tically (i.e., to management). <fnref n="44" /> For that model to work, two require-
ments are essential. First, an accurate monitoring system should be
in place for documenting decisions, products, policies, actions, and
transactions. Second, the infrastructure must allow for (where pos-
sible) unrestricted, timely, and transparent information flow and ac-
cess to information. To turn around neglect of information, gov-
erning information becomes an important domain of organizational
governance. With the emergence of big data, the relevance and im-
portance of information itself has become more apparent to organ-
izational leaders. In literature, the ability to govern, manage, and

<footnote n="44">⁴⁴ T.D. Stratton, D.W. Rudy, M.J. Sauer, J.A. Perman, and C.D. Jennings (2007). ‘Lessons from industry. One school’s transformation toward ‘lean’ curricular governance’, *Academic Medicine*, Vol. 82, No. 4, pp. 331–340.</footnote>
harvest quality information is emphasized to be of critical impor-
tance to organizational success in the big data era.<fnref n="45" /> The impact of
[1] e-discovery in litigation; [2] the preservation of information for
future use; and [3] an increasing number of data breaches, forces or-
ganizational leaders to embed information policies in organizational
governance, to supervise and control information as an asset, and to
implement structured approaches of information management.<fnref n="46" />

In this process, organizational leaders have become aware of the
fact that they do have control over *information systems* but lack con-
trol over the (quality of the) *information* captured within these sys-
tems. <fnref n="47" /> As long as information technology has been used in organ-
izations, the key driver in management *practice* have been infor-
mation systems instead of the information processed within them.
Scholarly and management literature since the early 1970s recog-
nized the critical value of *information* but translated this value into

<footnote n="45">⁴⁵ Van Bussel (2018), pp. 43–47; R F. Smallwood (2014). *Information Governance. Concepts, Strategies, and Best Practices*, John Wiley & Sons, Hoboken (NJ), p. 3. For the management necessity: A. McAfee, E. Brynjolfsson, T.H. Davenport, D.J. Patil, and D. Barton (2012). ‘Big data. The management revolution’, *Harvard Business Review*, Vol. 90, No. 10, pp. 60–68.</footnote>

<footnote n="46">⁴⁶ M.A. Adams, and S. Bennett (2018). ‘Corporate governance in the digital economy. The critical importance of information governance’, *Governance Directions*, Vol. 70, No. 10, pp. 631–639. Online source, retrieved on November 19, 2021, from: https://www.sibenco.com/corporate-governance-in-the-digital-economy.</footnote>

<footnote n="47">⁴⁷ Van Bussel (2020), pp. 59–60. A. Lucas (2019). ‘Critical success factors for corporate data quality management’, Á. Rocha, H. Adeli, L. Reis, and S. Costanzo (eds.), *New Knowledge in Information Systems and Technologies. WorldCIST'19 2019. Advances in Intelligent Systems and Computing*, vol 930, Part I, Springer, Cham, pp. 630–644. My own experiences in consulting organizational boards indicate a change in questions, from information technology quality questions to information (management) quality ones.</footnote>
information *technology* value and perspectives. Information manage-
ment, the way how information is created, used, processed, distrib-
uted, accessed, archived, and managed, and how it adds business
value, was, largely, neglected. <fnref n="48" /> But already in 2001, it was (at least
for accountability) convincingly asserted that it is not the access to
information systems that is essential, but to information itself. <fnref n="49" />
Although organizational leaders are still focused on management of
information systems, they are becoming very aware of their lack of
control over information and information *processes*, and, as a result,
they have great doubts whether the information they are using for
decision-making is relevant and of good quality. <fnref n="50" /> That doubt is
substantiated, for instance, by one of the conclusions of the Gartner
Marketing Data and Analytics Survey of October 2020. According
to this report, poor data quality has a negative impact on the useful-
ness of marketing analytics. <fnref n="51" /> Organizational leaders are becoming
aware of the fact that their lack of control has (large) financial con-

<footnote n="48">⁴⁸ Smallwood (2014), pp. 3–4. See, for instance: M.E. Porter, and V.E. Mil-
lar (1985). ‘How information gives you competitive advantage’, *Harvard
Business Review*, Vol. 63, No. 4, pp. 149–160, and S.E. Madnick, R.Y.
Wang, Y.W. Lee, and H. Zhu (2009). ‘Overview and framework for data
and information quality research’, *Journal of Data and Information Quality*
Vol. 1, No. 1, Article 2, pp. 1–22. Online source, retrieved on November
19, 2021, from: https://dl.acm.org/doi/pdf/10.1145/1515693.1516680?</footnote>

<footnote n="49">⁴⁹ K. Barata, and P. Cain (2001). ‘Information, not technology, is essential to accountability. Electronic records and public-sector financial management’, *The Information Society*, Vol. 17, No. 4, pp. 247–258.</footnote>

<footnote n="50">⁵⁰ Pirson, and Turnbull (2011), p. 460.</footnote>

<footnote n="51">⁵¹ G. Omale (2020). ‘Marketing Data and Analytics Survey 2020. Optimism perseveres as results fall short of expectations.’ Online source, retrieved November 19, 2021, from: https://www.gartner.com/en/marketing/in-sights/articles/gartner-marketing-data-analytics-survey-2020-analytics-fail-expectations.</footnote>
sequences. According to Gartner's 2017 Data Quality Market Survey, the average annual financial cost for an organization (in the United States) is approximately fifteen million dollars.<fnref n="52" /> A 2016 report of Royal Mail shows that more than half of British companies does not verify captured information and does not have an information quality policy. The resulting costs are, on average, almost six per cent of their annual revenue.<fnref n="53" /> Also in 2016, Tadhg Nagle, Thomas Redman, and David Sammon declared that only three per cent of an organization's information is in accordance with basic quality standards.<fnref n="54" /> Ana Lucas identified the critical success factors for information quality and recognized as crucial factors 'management commitment and leadership', 'information governance', and 'continuous information quality management improvement'.<fnref n="55" /> These factors imply a leading role for organizational leaders in embedding information governance within organizational governance. It is, of course, not as straightforward as it seems. With their focus predominantly on technology, the focus of organizational leaders

<footnote n="52">⁵² S. Moore (2018). ‘How to stop data quality undermining your business.’ Online source, retrieved November 19, 2021, from: https://www.gartner.com/smarterwithgartner/how-to-stop-data-quality-undermining-your-business/.</footnote>

<footnote n="53">⁵³ *The Six per cent Solution. How Better Customer Data Drives Marketing Performance and Business Growth.* Research Report, Royal Mail Group, London, 2016, p. 3. Online source, retrieved on November 19, 2021, from: https://www.royalmail.com/sites/default/files/RMDS-Research-Report-2017-Six-per-cent-solution.pdf.</footnote>

<footnote n="54">⁵⁴ T. Nagle, T.C. Redman, and D. Sammon (2017). ‘Only 3% of companies data meets basic quality standards’, *Harvard Business Review*, September 11. Online source, retrieved on November 19, 2021 from: https://hbr.org/2017/09/only-3-of-companies-data-meets-basic-quality-standards.</footnote>

<footnote n="55">⁵⁵ Lucas (2019), pp. 635–641.</footnote>
has been, for a long time, on governing information systems, their
performance, and risks.<fnref n="56" />

ICT governance

Most organizations have implemented ICT (or IT) governance
programs due to an assumed acknowledgement that information
technology is the foundation for organizational processes. It focuses
on ‘specifying the decision rights and accountability framework to
encourage desirable behaviour in the use of IT.’<sup>57</sup> It is a well-known
governance mechanism that is assumed to align information tech-
nology and business value.<sup>58</sup> However, realizing business value with
technical resources *alone* is not possible. Business value needs deci-
sions based on information. Yvonne Chan stated that in organiza-
tional practice aligning business and information technology is very
difficult to master. The results are not predictable because of their
dependency on ‘informal structures’ within organizations.<sup>59</sup> Even
when it ‘succeeds’, such an alignment can be harmful and mislead-

<footnote n="56">⁵⁶ Kooper, Maes, and Roos Lindgreen (2011), pp. 195–200.</footnote>

<footnote n="57">⁵⁷ To use the much-cited definition of: P. Weill, and J.W. Ross (2004). *IT Governance. How Top Performers Manage IT Decision Rights for Superior Results*. Harvard Business School Press, Boston, p. 8.</footnote>

<footnote n="58">⁵⁸ M.A.R.I.O. Spremić (2009). ‘IT governance mechanisms in managing IT business value’, *WSEAS Transactions on Information Science and Applications*, Vol. 6, No. 6, pp. 906–915.</footnote>

<footnote n="59">⁵⁹ Y.E. Chan (2002). ‘Why haven’t we mastered alignment? The importance of the informal organization structure’, *MIS Quarterly Executive*, Vol. 1, No. 2, pp. 97–112, especially p. 106–107. Informal structures are ‘relationship-based structures that transcend the formal division of labor and coordination of tasks.’ Chan’s study is based on eight case studies in which these informal structures (like social networks) proved very important for realizing organizational alignment and performance. See also: Van Bussel (2020), pp. 25–35, about (informal) relational climates and their effects.</footnote>
ing.<fnref n="60" /> As it is, ICT governance *only* addresses the way an organiza-
tion should take care of its information systems. It is a mechanism
to control information systems in such a way that they are compli-
ant to rules, routines, and policies, restricting their use, and even
(allegedly) stifle innovation.<fnref n="61" /> According to Luc Hoebeke, ‘govern-
ance’ is confronted with the ‘“unmanageability” of what it is sup-
posed to ‘govern”’.<fnref n="62" /> Finding balance between the ‘manageable’ and
the ‘unmanageable’ is impossible. Organizational leaders discourage
activities that transgress set boundaries, and /or even discard them
by using ‘governance’ as the ‘scape goat’. Established in this man-
ner, governance is used as a tool of repression.<fnref n="63" /> Besides these con-
siderations, there are three limitations to ICT governance.<fnref n="64" />

<footnote n="60">⁶⁰ See the scathing review of misleading management school research on ‘strategic alignment’: C. Ciborra (1997). ‘De profundis? Deconstructing the concept of strategic alignment’, *Scandinavian Journal of Information Systems*, Vol. 9, No. 1, pp. 67–82. On p. 79 he declares ‘strategic aligning’ to be a hype, badly researched, and set aside when a new hype emerges, just like many research projects of management schools. ‘This may justify the relentless succession of publications with data and models, but very little accumulation of new concepts that last.’</footnote>

<footnote n="61">⁶¹ G.G. Brenkert (2009). ‘Innovation, rule breaking and the ethics of entrepreneurship’, *Journal of Business Venturing*, Vol. 24, No. 5, pp. 448–464. Compliant to rules means that rule-breaking is prohibited. The core of Brenkert’s analysis (p. 462) is that without breaking (moral) rules, innovation is sometimes not possible. He states (p. 454): ‘an entrepreneur may believe that the rule is out-of-date, too limited, too narrow, ossified, of questionable relevance, or that it simply stands in the way of a valuable project. In such a case, the entrepreneur might decide to violate or circumvent the rule, but then to seek forgiveness afterwards.’</footnote>

<footnote n="62">⁶² L. Hoebeke (2006). ‘Identity. The paradoxical nature of organizational closure’, *Kybernetes*, Vol. 35, No. 1–2, pp. 65–75, p. 72.</footnote>

<footnote n="63">⁶³ Hoebeke (2006), p. 73.</footnote>

<footnote n="64">⁶⁴ Kooper, Maes, and Roos Lindgreen (2011), p. 196.</footnote>
The first (already mentioned) limitation is that ICT governance
is *not* concerned with information and is *only* focused on technol-
ogy resources and associated risks. A second limitation is that it *only*
focuses on the ‘control part’ of business (administration, policies,
responsibility, reporting, and auditing) and ignores the (just as es-
sential) ‘creative part’, embodying innovation, entrepreneurship,
creativity, and value creation. Kooiman declares creativity, intui-
tion, and experience to be just as important as goal-directness, effi-
ciency, and working ‘according to rules’.<fnref n="65" /> So, implementing ICT
governance to align technology with business processes might have,
ultimately, an opposite effect: widening the gap between business
and ICT instead of bridging it.<fnref n="66" /> The third limitation is a practical
one: practice shows that ICT governance is often implemented half–
heartedly. If it is implemented in full, it is restricted to the ICT or-
ganization and leads to a formal, bureaucratic environment

Governing information

Rick Maes emphasizes the value of information management as
the linking pin between business and information technology. His

<footnote n="65">⁶⁵ Kooiman (2003), p. 4.</footnote>

<footnote n="66">⁶⁶ J. Peppard, and J. Ward (1999), “Mind the Gap”. Diagnosing the relationship between the IT organisation and the rest of the business’, *The Journal of Strategic Information Systems*, Vol. 8, No. 1, pp. 29–60. Also: K. Kark, A.N. Phillips, B. Briggs, M. Lillie, J. Tweardy, S. Buchholz (2020). ‘The kinetic leader. Boldly reinventing the enterprise. Findings from the 2020 Global Technology Leadership Study’, *Deloitte Insights*, 18 May 2020. Online source, retrieved November 19, 2021, from: https://www2.deloitte.com/us/en/insights/topics/leadership/global-technology-leadership-study.html. In this paper the assertion is made ‘that the current gap between business expectation and the approach of technology leaders is more like a chasm.’</footnote>
reasons are related to the maturity of information technology that
led to [1] information-dependent organizations, struggling with in-
formation overload and information underuse, which is a motive to
manage information as a resource; [2] highly effective information
systems at the supply side that are confronted with a highly imma-
ture demand side as most organizations show, apart from their tech-
nological components, a serious lack of understanding of infor-
mation processes.<fnref n="67" /> Subsequently, Michiel Kooper, Rick Maes, and
Edo Roos Lindgreen observed that information is independent of
the information systems used, an intangible asset with very difficult
to measure costs and benefits and originating more and more from
external sources that surpass classical data formats.<fnref n="68" /> As such, the
management of information, from creation to preservation or dis-
posal, should be a subject for organizational governance. Organiza-
tions do not necessarily need *information systems*, but they do need
relevant *information* of good quality for decision-making or as evi-
dence of past and current actions and transactions. Information gov-
ernance is, thus, a 'must.'

There are many, largely similar, definitions for information gov-
ernance. <fnref n="69" /> I define information governance as that specific part of

<footnote n="67">⁶⁷ R. Maes (2007). ‘An integrative perspective on information management’, A. Huizing, and E.J. de Vries (eds.), *Information Management. Setting the Scene*. Perspectives on Information Management, Volume 1, Emerald Group Publishing Limited, Bingley, Chapter 1, pp. 11–26, p. 11–12.</footnote>

<footnote n="68">⁶⁸ Kooper, Maes, and Roos Lindgreen (2011), p. 195.</footnote>

<footnote n="69">⁶⁹ Gartner defines information governance as: ‘The specification of decision rights and an accountability framework to encourage desirable behavior in the valuation, creation, storage, use, archival and deletion of information, including the processes, roles, standards and metrics that ensure the effective and efficient use of information in enabling an organization to achieve its goals.’ Gartner Glossary, *Information Technology, Information Governance*. Online source, retrieved om November 19, 2021, from:</footnote>
organizational governance, that functions as ‘operating system’ for
information management (including rules, decision-making rights,
security and risk parameters), and that realizes the governing of in-
teractions defining the coordination and control environment for
the valuation, creation, collection, analysis, distribution, storage, re-
tention, disposal, preservation, and use of information.⁷⁰ Such an
extensive information governance ‘operating system’ as part of or-
ganizational governance is missing in most organizations.⁷¹

https://www.gartner.com/en/information-technology/glossary. The As-
sociation of Records Managers and Administrators (ARMA), defines infor-
mation governance as ‘the overarching and coordinating strategy for all
organizational information, establishing the authorities, supports, process-
es, capabilities, structures, and infrastructure to enable information to be a
useful asset and reduced liability to an organization, based on that organi-
zation’s specific business requirements and risk tolerance.’ *Glossary of Rec-
ords and Information Management Terms*, ARMA International, Overland
Park (Ks.), 2016, fifth edition.

⁷⁰ Based on: Kooper, Maes, and Roos Lindgreen (2011), p. 195–196, Adams, and Bennett (2018), p. 633–634, and Kooimans (2003), pp. 11–25.

⁷¹ According to Adams, and Bennett (2018), 635–636, knowing where in-
formation is and mapping it, is a first step, followed by securing and con-
trolling it. They assert that in 2018, these steps are significant challenges. A
2008 briefing states that only thirty-eight per cent of surveyed companies
have an information governance strategy in place. *The future of enterprise
information governance*, The Economist Intelligence Unit Ltd, London,
2008, p. 2. Online source, retrieved on November 19, 2021, from:
http://graphics.eiu.com/files/ad_pdfs/EMC_InfoGovernance.pdf. A re-
port on information governance maturity from 2021 shows that thirty-
three per cent of surveyed organizations have an information governance
program ‘in development’, thirty-seven per cent have realized the ‘Essen-
tials’, and twenty per cent is ‘Pro-active’. Seven per cent has a sub-standard
information governance program. Most developed are ‘Infrastructure’ (in-
formation systems) and ‘Authorities’ (compliance). ARMA (2021). *Infor-
Directing information management

Referring to the governing modes Kooiman identified, infor-
mation governance will often be based on hierarchical governance.
The different degrees of bureaucracy and the many variables and
mixes of variables (as proposed by Thorsteinsen) offer possibilities
for governing information.<fnref n="72" /> Whatever mode of governance is used,
the volatility of information makes controlling its use and exchange
difficult. Governing and control of information is possible when
organizational interactions and the information within those inter-
actions are known and embedded within a flexible, adaptive infor-
mation management environment, focused on interactions, sense-
making context, and the ways people use and exchange information.

Within this information management environment, ICTs are in-
valuable technical resources that are facilitating the information
within those systems to realize business value. As is emphasized be-
fore, information is the linking pin between business processes, and
ICT. <fnref n="73" /> Organizational leaders should design information govern-
ance structures as the ‘operating system’ for enterprise information
management in which interactions and sensemaking contexts are
operationalized. Information governance, as a subset of organiza-

<footnote>*Government Maturity Index Report 2021*, ARMA, Overland Park (Ks.), p. 24. None of these surveys asks if organizations know what information they have and where to find it. About the difficulty of finding information: Van Bussel (2020), pp. 59–61.</footnote>

<footnote n="72">⁷² Kooiman (2003), Chapters 6–8, pp. 77–131; Thosteinsen (2012), p. 324.</footnote>

<footnote n="73">⁷³ G.J. Van Bussel (2016). ‘An accountability challenge. Capturing records and their context in enterprise information systems’, P. Silva, A. Guerreiro and R. Quaresma (eds.), *Proceedings of the 10th European Conference of Information Systems Management. ECISM 2016, Evora, Portugal, 8-9 September 2016*, ACPI, Reading, pp. 204-211; Kooper, Maes, and Roos Lindgreen (2011), p. 195.</footnote>
tional governance, can then be used *to direct* information and enterprise information management.<fnref n="74" /> Within information governance, organizational leaders should define and continuously evaluate the conditions for ‘trusted interactions’<fnref n="75" /> and ‘sensemaking interactions’<fnref n="76" /> between the multiple (very much siloed) disciplines concerned with information, enterprise information management, and information risks. This would reduce duplicate work, redundancies, policy-making, communication, and reporting.

It should be clear that information governance and information management are not the same. Information governance (as a subset of organizational governance) is *directing* information management as its ‘operating system’. Information management is managing organizational information, trying to optimize information value, and assuring information access over time, based on information governance structures.

## ALIGNING PERFORMANCE AND ACCOUNTABILITY

********

According to academic literature, governance reforms to have more stringent accountability structures enhance justice, transparency, appropriate behaviour, and performance. It is assumed that employees that are held to account for their behaviour perform better.<fnref n="77" /> Melvin Dubnick contends that this assumption has been ac-

<footnote n="74">⁷⁴ J. Hagmann (2013). ‘Information governance – beyond the buzz’, *Records Management Journal*, Vol. 23, No. 3, pp. 228–240, p. 230.</footnote>

<footnote n="75">⁷⁵ Hagmann (2013), p. 231.</footnote>

<footnote n="76">⁷⁶ Kooper, Maes, and Roos Lindgreen (2011), p. 197.</footnote>

<footnote n="77">⁷⁷ M.J. Dubnick (2002). ‘Seeking salvation for accountability’. *Paper presented at the Annual Meeting of the American Political Science Association,*</footnote>
cepted too easily.<fnref n="78" /> This may be true: the evidence is, overall, in-
conclusive. Yousueng Han and Sounman Hong summarize prior
research that identified cases that indicated that accountability im-
proves performance in specified tasks and processes and add some
tasks and processes to these positives. They are, however, clear that
‘too much accountability’ may negatively affect performance.<fnref n="79" /> It
is what Dubnick calls the ‘accountability paradox’: when there are
multiple accountability demands, implementation of these (some-
times contradictory) demands may affect performance negatively.<fnref n="80" />

August 29–September 1, 2002, American Political Science Association, Boston, pp. 16–17. Online source, retrieved on November 19, 2021, from: http://mjdubnick.dubnick.net/papersrw/2002/salv2002.pdf; M.J. Dubnick (2005). ‘Accountability and the promise of performance. In search of the mechanisms’, *Public Performance and Management Review*, Vol 28, No. 3, pp. 376–417, pp. 376–377; M.J. Dubnick, and J.B. Justice (2004). ‘Accounting for accountability’. *Paper presented at the Annual Meeting of the American Political Science Association*, Chicago, Sept. 2, 2004, p. 6. Online source, retrieved on November 19, 2021, from: http://mjdubnick.dubnick.net/papersrw/2004/dubjusacctg2004.pdf; R. Zumofen (2015). ‘Redefining accountability in a strategic perspective to enhance performance’. *Paper prepared for the 2015 International Research Society for Public Management conference, Panel L 101, Open Panel*, University of Birmingham, 30 March–1 April 2015. Online source, retrieved on November 19, 2021, from: https://www.academia.edu/11860410/Redefining_accountability_in_a_strategic_perspective_to_enhance_performance.

<footnote n="78">⁷⁸ Dubnick (2005), pp. 395–397.</footnote>

<footnote n="79">⁷⁹ Y. Han, and S. Hong (2019). ‘The impact of accountability on organiza-
tional performance in the U.S. Federal Government. The moderating role
of autonomy’, *Review of Public Personnel Administration*, Vol. 39, No. 1,
pp. 3–23, p. 6. Similar conclusions: T. Christensen, and P. Lægreid (2015).
‘Performance and accountability. A theoretical discussion and an empirical
assessment’, *Public Organization Review*, Vol. 15, No. 2, pp. 207–225.</footnote>

<footnote n="80">⁸⁰ Dubnick (2005), p. 396.</footnote>
On the other hand, when the focus is on performance and produc-
tivity improvement, it could lead to the accountability disaster that
the financial crisis of 2008 turned out to be. The interaction be-
tween accountability and performance can be characterized by am-
biguities, contradictions, and myths. Although this interaction has
been a topic of research, there is no answer that solves those ambi-
guities. The reason is that the performance-accountability compar-
ison is based on wrong assumptions. Accountability is presented as
a tool of organizational governance, but it is not a tool, an instru-
ment, but an objective of organizational governance. <fnref n="81" /> As a tool, its
influence on performance can be direct, as an objective, that influ-
ence is indirect. Accountability is based on extra-organizational ex-
pectations and requirements (expressed in laws, regulations, stand-
ards, and professional codes of ethics) that can be contrary to the
goals of another objective of organizational governance: perfor-
mance. It is not as much a question of accountability being ‘good’
or ‘bad’, but of both objectives being balanced in practice and in the
controls of organizational governance. <fnref n="82" />

<footnote n="81">⁸¹ M.J. Dubnick (2006). ‘Performance as a false promise of accountability. The case of American schools.’ *Paper for presentation at Vienna Workshop on Achieving School Accountability in Practice*, University of Vienna, February 15–17, 2006. Online source, retrieved on November 19, 2021, from: http://mjdubnick.dubnick.net/papersrw/2006/vienna021306.pdf. Dubnick explores the use of accountability within New Public Management and its emphasis on the relationship between accountability and performance. He states: ‘Accountability is not a tool of governance, but rather a condition of being governed. It is the object of the instrument rather than the instrument itself.’ See also: Dubnick (2005).</footnote>

<footnote n="82">⁸² S.I. Lindberg (2013). ‘Mapping accountability. Core concept and sub-types’, *International Review of Administrative Sciences*, Vol. 79, No. 2, 202–226, p. 217. See also: R.D. Behn (1998). ‘The new public management para-</footnote>
Finding a balance between the efforts of being accountable and the efforts for enhancing organizational performance will be a challenge. Both objectives interact and compete for attention and resources. When not balanced, they will have detrimental effects upon each other. Being accountable means that performance can only be enhanced within the limits allowed for by the accountability manifestations the organization wants to tackle. Enterprise information management could help in finding such a balance.

As was mentioned here before, governance is about ‘processes of information flow, decision-making, decision-implementation, and decision-monitoring’, to enhance both performance and accountability. Governance is about governing interactions in which information itself, the sense-making processes that follow the use of this information, and information management, are crucial. It is in those interactions and their control structures where balance could be created. The consequences for both objectives (and ways to handle them) should be considered for all decisions, rules, and routines. In information governance, the requirements for both performance and accountability need to be considered and evaluated. For accountability, information governance should include an identification of each accountability manifestation, its requirements and demands for explanation, the information needed to respond, the definition of responses, a description of its environment, and the selection of its instruments (like processes, systems, and rules.<fnref n="83" /> The operationalization of information governance, however, is dependent on the willingness of organizational leaders to consciously accept information as a vital business asset, to continually reconfirm its

<footnote>digm and the search for democratic accountability', *International Public Management Journal*, Vol. 1, No. 2, 131-164,</footnote>

<footnote n="83">⁸³ Zumofen (2015), pp. 11-15.</footnote>
value in their organizations, to require discipline and rigour in the
use and management of information, and to embed information
management in the organizational control environment. This is a
behavioural challenge, for leaders as well as all other employees of
the organization.

RULES AND ROUTINES

********

Rules and routines are important control mechanisms. They are
prominent subjects both for organizational performance and organ-
izational accountability. <fnref n="84" /> Rules fulfil an important function within
organizational governance as they are the ‘formally recognised way
in which ‘things should be done.’” <fnref n="85" /> Many rules are based on laws
and government regulations. Organizational leaders also use (and
enforce) rules not based on laws and regulations to direct and coor-
dinate actions of employees, departments and teams, trying to align

<footnote n="84">⁸⁴ Gilson (2018), p. 8. For rules and routines: J.C. Weichbrodt (2013). *Rules and Routines in Organizations and the Management of Safety Rules*. ETH Zürich Research Collection, Dissertation Nr. 20956, Part 1, pp. 4–5. Online source, retrieved on November 19, 2021, from: https://doi.org/10.3929/ethz-a-009752785. See also: J.C. Weichbrodt, and G. Grote (2010). ‘Rules and routines in organizations. A review and integration’. *Paper presented at the Fourth International Conference on Organizational Routines*, June 11–12 2010, Nice. Online source, retrieved on November 19, 2021, from: http://www.gredeg.cnrs.fr/routines/Workshop-Nice-2010/papers/Weichbrodt%20and%20Grote.PDF.</footnote>

<footnote n="85">⁸⁵ J.E. Burns, and R.W. Scapens (2000). ‘Conceptualising management accounting change. An institutional framework’, *Management Accounting Research*, Vol. 11, No. 1, pp. 3–25, p. 6.</footnote>
their behaviour with organizational objectives. Rules constitute a control and coordination mechanism assisting in the definition of responsibilities, the allocation of resources, and in the development of collective agreement about organizational problems. <fnref n="86" /> Often, rules result from an assessment of alternatives, and are defined to avoid the costs of continuous assessments. <fnref n="87" /> They protect, coordinate, channel, and limit efforts. They provide ‘sanctuary for the intrepid.’ They maintain stability but may also retard or stimulate change. Complaints about rules are often results of deep-seated organizational problems that cannot easily be solved. <fnref n="88" /> In cultures and climates that emphasize the ‘letter of the law’ rule-bending and rule-breaking occur every day. <fnref n="89" />

By following rules in organizational practice repeatedly, employee behaviour may become programmatic and, as such, could be described as routines, ways in which ‘things are actually done,’ or a ‘repetitive and recognizable pattern of independent actions, involving multiple actors.’ <fnref n="90" /> Individual actors, based on their personal perceptions and interpretations, are influencing the collective un-

<footnote n="86">⁸⁶ Weichbrodt (2013), p. 4–5; Weichbrodt and Grote (2010), p.2.</footnote>

<footnote n="87">⁸⁷ Burns, and Scapens (2000), p. 6.</footnote>

<footnote n="88">⁸⁸ Ch. Perrow (1986) *Complex Organizations. A Critical Essay*, Newbery Award Records, New York (third edition), pp. 25–26.</footnote>

<footnote n="89">⁸⁹ J.F. Veiga, T.D. Golden, and K. Dechant (2004). ‘Why managers bend company rules’, *Academy of Management Perspectives*, Vol. 18, No. 2, pp. 84–90, and E.L. Borry (2017). ‘Ethical climate and rule bending. How organizational norms contribute to unintended rule consequences’, *Public Administration*, Vol. 95. No. 1, pp. 78–96.</footnote>

<footnote n="90">⁹⁰ Respective citations: Burns, and Scapens (2000), p. 6, and M.S. Feldman, and B.T. Pentland (2003). ‘Reconceptualizing organizational routines as a source of flexibility and change’, *Administrative Science Quarterly*, Vol. 48, No. 1, pp. 94–118, p. 95.</footnote>
derstanding of a routine.<fnref n="91" /> The ways things are ‘actually done’ may not be the same as the way things ‘should be done’, and it may even be possible that routines (based on the same rule) may be different between teams, work groups, and places of work within the same organization, and/or may have deviated considerably from the original rules.<fnref n="92" /> Routines may even emerge (especially in the relational climates of work groups, teams, or places of work) which were never set out in organizational rules. In such cases, organizational leaders (to enhance control) may decide to formalize the established routines in a set of rules and procedures. It is clear, that a two-way relationship exists between rules and routines.<fnref n="93" />

Many rules and procedures are computerized: they are configured within information systems to provide guidance and support for organizational tasks.<fnref n="94" /> These system configurations are always

<footnote n="91">⁹¹ Feldman, and Pentland (2003), pp. 108–109.</footnote>

<footnote n="92">⁹² Burns, and Scapens (2000), p. 6–7 ('should be done'), and Van Bussel (2020), p. 42–43, p. 52. About personal perceptions and interpretations: Van Bussel (2020), pp. 25–35.</footnote>

<footnote n="93">⁹³ Burns, and Scapens (2000), pp. 6–7. Also: M. Quinn (2011). ‘Routines in management accounting research. Further exploration’, *Journal of Accounting and Organizational Change*, Vol. 7, No. 4, pp. 337–357, pp. 347–349. This relationship leads to differing interpretations. Quinn (2011), p. 344, defines rules primarily ‘as a physical representation of a routine, which are formalised in a documented fashion and may serve to guide action.’ The way ‘things are actually done’ are formalized and become the way ‘things should be done.’ That way, organizational routines are viewed as the origin of rules, not the other way around, as Burns and Scapens (2000), p.6, do. Quinn (2011) views rules as artefacts of routines, as proposed by: B. Pentland, and M. Feldman (2008), ‘Issues in field studies of organizational routines’, M.C. Becker (ed.), *Handbook of Organizational Routines*, Edward Elgar, Cheltenham, Chapter 13, pp. 281–300, pp. 289–290.</footnote>

<footnote n="94">⁹⁴ Weichbrodt (2013), pp. 40–43.</footnote>
as ‘things should be done’. Ideally, rules and procedures reduce com-
plexity and simplify decision-making. They do, but they are also
restrictive, and (when combined with formal and informal penalties
for violations, as they usually are <sup>95</sup>) seriously reducing freedom of
choice. This constraining aspect (especially when there are many
rules and procedures) is strengthened when the ways ‘things are ac-
tually done’ deviate from the computerized ways ‘things should be
done’. Information systems can be perceived by employees as rigid
and inert, delaying change and adaptation of old procedures to new
circumstances, leading to routines that harbour serious behavioural
(information) problems. ‘Retrospective inscribing’ is an example. <sup>96</sup>
These perceptions cause resistance and rule violations, potentially
indicating a need for change, <sup>97</sup> but most likely leading to two poten-

<footnote n="95">⁹⁵ Weichbrodt (2013), pp. 35–36. Formal and informal penalties realize so-
sialization, even if ‘need for change’ is being espoused by organizational
leaders. For ‘espoused values’: Van Bussel (2020), p. 39.</footnote>

<footnote n="96">⁹⁶ For behavioural problems for enterprise information management: Van Bussel (2020), pp. 61–65, and p. 90. I introduced ‘retrospective inscribing’ for capturing exchanges in information systems *after the event* itself, presenting the exchange as if the prospectively defined computerized procedures were realized. Many respondents in my audit projects impress the fact that, although information systems could make work easier in routinized and structured processes, they are detailed, demanding, and presenting a non-existent reality. Discussing cases with colleagues, reaching agreement, and registering outcomes retrospectively in a system is easier. It becomes a ‘routine’, against formal rules, when accepted by management.</footnote>

<footnote n="97">⁹⁷ T. Olin, and J. Wickenberg (2001). ‘Rule breaking in new product development. Crime or necessity?’, *Creativity and Innovation Management*, Vol. 10, No. 1, pp. 15–25. Change will not happen often: ‘Written rules are repositories of organizational lessons, but the learning that deposits new lessons into rules and remove old ones is notorious for generating myopic, path-dependent, and inefficient histories’, as stated by: J.G. March, M.</footnote>
tial management solutions: the first is to accept the behavioural problems as they are (which happens often when ‘only’ information is ‘at stake’) or, second, a definition of *more* rules trying to prevent violations which limits the freedom of choice even more. ⁹⁸ Organizations, after all, do have a tendency to continuously create more rules and procedures (‘red tape’), although the production of new rules slows down as more rules are already in place. ⁹⁹ Too many rules and procedures could lead to performance problems, insoluble accountability questions, and contrasting information policies because of conflicting responsibilities, different rule interpretations

Schulz, and X. Zhou (2000). *The Dynamics of Rules. Change in Written Organizational Codes*, Stanford University Press, Stanford, p. 2.

⁹⁸ For accepting behavioural information problems: Van Bussel (2020), pp. 61–65. For limiting ‘freedom of choice’: R.L. Heidelberg (2017). ‘Political accountability and spaces of contestation’, *Administration & Society*, Vol. 49, No. 10, pp. 1379–1402, and C. O’Kelly, and M.J. Dubnick (2019). ‘Dissecting the semantics of accountability and its misuse’, H.L. Paanakker, A. Masters, and L. Huberts (eds), *Quality of Governance. Values and Violations*, Palgrave Macmillan, London, Chapter 3, pp. 45–80.

⁹⁹ B. Bozeman (1993). ‘A theory of government red tape’, *Journal of Public Administration Research and Theory*, Vol. 3, No. 3, pp. 273–303, p. 283, defines ‘red tape’ as: ‘rules, regulations and procedures that remain in force and entail a compliance burden for the organization but make no contribution to achieving the rules’ functional objectives.’ Most organizations are multilayer entities, showing aspects of many models of government and, as such, many different types of ‘red tape’: B. George, S.K. Pandey, B. Steijn, A. Decramer, and M. Audenaert (2020). ‘Red tape, organizational performance and employee outcomes. Meta-analysis, meta-regression and research agenda’, *Public Administration Review*. Online source, retrieved on November 19, 2021, from: https://doi.org/10.1111/puar.13327. Slowing down rule-production: M. Schulz (1998). ‘Limits to bureaucratic growth. The density dependence of organizational rule births’, *Administrative Science Quarterly*, Vol. 43, No. 4, pp. 845–876, pp. 872.
between teams and work groups, and discrepancy with existing rou-
tines. Information systems should, ideally, allow for better account-
ability but when computerized rules and procedures become rigid
and inert, they may lead to accountability problems. They do not
mirror the ‘actual way things were done’ but only the computerized
way ‘things were done’ earlier in time. If ‘retrospective inscribing’
also happens for those rules and procedures that are required by law
and government regulations, non-compliance could become a prob-
lem. Rules and routines are an important mechanism for infor-
mation governance, because operationalization of rules and routines
*always* concerns information.

Rule-bending means the willing and knowing ‘depart[ure] from
rules and procedures’ and ‘involves a decision to go around the for-
mally stated obligations by not fully following a rule, requirement,
procedure or specification.’ <fnref n="100" /> ‘Retrospective inscribing’ is an exam-
ple of such rule-bending. Although most employees generally fol-
low rules, deviations are relatively common. <fnref n="101" /> It may be perceived
as deviant behaviour that ‘violates significant organizational norms
and, in so doing, threatens the well-being of an organization, its
members, or both.’ It may include, as examples, sabotage, fraud,

<footnote n="100">¹⁰⁰ For the respective citations: L. DeHart-Davis (2007). ‘The unbureaucratic personality’, *Public Administration Review*, Vol. 67, No. 5, pp. 892–903, p. 893, and L.E. Sekerka, and R. Zolin (2007). ‘Rule-bending. Can prudential judgment affect rule compliance and values in the workplace?’, *Public Integrity*, Vol. 9, No. 3, pp. 225–243, p. 228.</footnote>

<footnote n="101">¹⁰¹ DeHart-Davis (2007), pp. 893-894, and J. Larsson, and J. Ramstedt (2013). *Learning How to Break Rules. An Exploration of Why Organizations still Function Despite Dysfunctional Rules*. Master's thesis in Software Engineering, Chalmers University of Technology, Gothenburg, pp. 64-66. Online source, retrieved on November 19, 2021, from: https://odr.chalmers.se/handle/20.500.12380/220586,</footnote>
stealing, vandalism, or sexual harassment, potentially out of self-interest, for instance when employees withhold, alter, fabricate, or destroy information trying to hide worsening product performance to ensure their remuneration. <fnref n="102" /> It may be even a self-interested, harmless response to obstacles, like a perception of ‘red tape’, pressures to reach ambitious objectives, or restrictive information systems. Positive perceptions (‘positive deviance’) imply that rule-bending may result from good intentions and could bring positive results. <fnref n="103" /> ‘Pro-social rule breaking’, for instance, occurs when employees intentionally violate ‘a formal organizational policy, regulation, or prohibition with the primary intention of promoting the welfare of the organization or one of its stakeholders.’ <fnref n="104" /> There are reasons for such behaviour: efficiency, wanting to help a colleague, or for customer service. Employees choose to ignore, bend, or break a rule for the benefit of the organization. It is, mostly, not accepted because, as Shannon Portillo emphasized, although it ‘is portrayed as part of a push for entrepreneurial leadership in organizations, and is individually admired, but seen as collective action it goes against the formal structure and public values’ of organizations. <fnref n="105" /> Non-

<footnote n="102">¹⁰² Citation: S.L. Robinson, and R.J. Bennett (1995). ‘A typology of deviant workplace behaviors. A multidimensional scaling study’, *Academy of Management Journal*, Vol. 38, No. 2, pp. 555–572, p. 556. Examples: Robinson, and Bennett (1995), p. 565 and p. 571; Borry (2017), pp. 80–81. Remuneration: Argandona (2012), p. 3.</footnote>

<footnote n="103">¹⁰³ G.M. Spreitzer, and S. Sonenshein (2004). ‘Toward the construct definition of positive deviance’, *American Behavioral Scientist*, Vol. 47, No. 6, pp. 828–847, p. 828.</footnote>

<footnote n="104">¹⁰⁴ E.W. Morrison (2006). ‘Doing the job well. An investigation of pro-social rule breaking’, *Journal of Management*, Vol. 32, No. 1, pp. 5–28, p. 6.</footnote>

<footnote n="105">¹⁰⁵ Reasons for behaviour: Morrison (2006), p. 10. Not accepted positive rule-bending: S. Portillo (2012). ‘The paradox of rules’, *Administration & Society*, Vol. 44, No. 1, pp. 87–108, p. 90.</footnote>
acceptance especially occurs in organizations with centralized struc-
tures and a stringent rules strategy. Rule-bending here, however, is
a normal phenomenon. <fnref n="106" />

Studying the problem of rigid rules, Jens Rasmussen stated that in rules boundaries should be defined within which routines can vary and change, without leading to violations. He argued that ‘the focus should be on the control of behaviour by making the boundaries explicit and known and by giving opportunities to develop coping skills at boundaries.’<fnref n="107" /> Rasmussen proposes the implementation of rules but allowing change and variety in routines.

The rule classification defined by Andrew Hale en Paul Swuste
could help in such an endeavour. They recognize three main types
of rules that all influence and are influenced by the method used to
establish compliance and enhance performance. <fnref n="108" /> These rule types,
the resulting employee behaviour, and the compliance methods
used, influence performance and accountability. Hale and Swufte
recognize, first, *rules that define goals to be achieved*. Such a rule al-
lows employees freedom of choice in their routines, as the rule does
not define *how* the objectives should be achieved. To be effective, it
should be possible to measure the result. If it cannot be measured,
assessing obedience is checking *what* employees have done and *how*
they decided to do it. This transforms the rule into one of the other
two types of rules. <fnref n="109" /> This type of rule leaves the possibility that
objectives are realized in unethical ways. Organizational leaders, af-

<footnote n="106">¹⁰⁶ DeHart-Davis (2007), pp. 895-896.</footnote>

<footnote n="107">¹⁰⁷ J. Rasmussen (1997). 'Risk management in a dynamic society. A modeling problem', *Safety Science*, Vol. 27, No. 2-3, pp. 183-213.</footnote>

<footnote n="108">¹⁰⁸ A.R. Hale, and P. Swuste (1998). ‘Safety rules. Procedural freedom or action constraint?’, *Safety Science*, Vol. 29, Nr. 3, pp. 163–177, especially pp. 165–167.</footnote>

<footnote n="109">¹⁰⁹ Hale, and Swuste (1998), p. 166.</footnote>
ter all, often put (excessive) pressure on employees to reach perfor-
mance targets. This pressure often leads to unethical behaviour in
order to reach those goals, especially if employees perceive them as
unrealistic, or if they feel not psychologically safe. <fnref n="110" /> It could, when
stimulated with a very competitive incentives schedule, lead to ex-
tremely unethical behaviour, greed, fraud, and information manip-
ulation, and may result in short-termism. This type of rule is fo-
cused on enhancing performance.

The second rule type Hale and Swufte recognized are *solution search rules*, rules that define *by whom* and *how* a decision about a course of action has to be reached. They define procedures about the employee roles involved, the methods and standards used, the parameters to be considered in judging appropriateness, the time frame available for finding solutions, and the information needed to be captured at predetermined stages of the procedure. They partly define routines but, using procedural milestones, they leave details more or less open. Assessing obedience means checking whether procedures have been followed and evaluating the captured information and the quality of decisions. <fnref n="111" /> This rule type may balance performance and accountability.

The third rule type are *rules defining concrete actions or required states of a system*. These rules specify (more or less in detail) the routines and behaviour to be shown in a defined or implied situation, or a state of affairs to be achieved. They remove freedom of choice, though the wording may leave room for interpretation. Checking compliance is a matter of observing behaviour or measuring the

<footnote n="110">¹¹⁰ L.D. Ordóñez, M.E. Schweitzer, A.D. Galinsky, and M.H. Bazerman (2009). ‘Goals gone wild. The systematic side effects of overprescribing goal setting’, *Academy of Management Perspectives*, Vol 23, No. 1, pp. 6–16. For psychological safety: Van Bussel (2020), pp. 29–30.</footnote>

<footnote n="111">¹¹¹ Hale, and Swuste (1998), p. 166.</footnote>
state of the system, the presence and functioning of required hard-
ware, the specified information captured, etc. <fnref n="112" /> This type of rule is
believed to impose a regulatory and performance burden, because
detailed definitions create many exceptions to which the rule does
not, or cannot, apply, and lead to deviations when existing routines
and rules are contrasting. <fnref n="113" /> They also generate information systems
that are extremely rigid and restrictive. They do not allow employ-
ees freedom of choice. These rules are focused on compliance to ac-
countability requirements.

Rules are progressive limitations of the freedom of choice in rou-
tines, first limiting goals, then decision-making, and finally the ac-
tions themselves. The more compliance is emphasized, the more
they are perceived by employees as (unjustifiably) limiting their
freedom of choice, possibly leading to rule deviation and retrospec-
tive inscribing. All rule types are applicable in organizations, de-
pending on the level of compliance required by law. Regulations
can be viewed in a continuum with four levels, each level defining
more stringent regulations and requiring stricter compliance: no-
regulation, self-regulation, co-regulation, and statutory regulation.

¹¹⁴ In organizational governance (and its information governance part) these four regulation levels need to be aligned with the three recognized rule types. In this alignment, for each regulation level needs to be defined the dominant rule type, the freedom of choice

<footnote n="112">¹¹² Hale, and Swuste (1998), p. 167–168.</footnote>

<footnote n="113">¹¹³ A. Hale, D. Borys, and M. Adams (2015). ‘Safety regulation. The lessons of workplace safety rule management for managing the regulatory burden’, *Safety Science*, Vol. 71, Part B, pp. 112–122, p. 115.</footnote>

<footnote n="114">¹¹⁴ F. Nakpodia, E. Adegbite, K. Amaeshi, and A. Owobilabi (2018). ‘Neither principles nor rules. Making corporate governance work in Sub-Saharan Africa’, *Journal of Business Ethics*, Vol. 151, pp. 391–408, especially p. 393.</footnote>
employees have in routines within that specific level, the levels of
compliance required for each regulation level, the level of rule-
bending accepted in specific, pro-social situations and its limits, <fnref n="115" />
the way rules and routines are changed when the environment
changes, the way information management should be organized, the
way how information systems should be configured for each level
of regulation and changed when necessary, and the ways employees
are accountable for their behaviour in each level. This needs to be
continuously communicated to employees, and embedded in organ-
izational culture and relational climates. Especially for the level of
statutory regulation, where compliance is the dominant force, em-
ployees need to be stimulated by their team, work group, and/or
place of work to be compliant. By embedding this approach in cul-
ture and climates, organizational leadership makes rule boundaries
explicit for all regulation levels, and routines can vary and change
when needed. This would allow Rasmussen’s solution to be imple-
mented, also within the control structure of the organization.

THE ETHICS OF ACCOUNTABLE GOVERNANCE

********

Without doubt, strategies, rules, routines, systems, and proce-
dures are important for accountable governance, but it is especially
an ethical and behavioural challenge. Both organizational govern-
ance and organizational ethics are deemed essential for long-term

<footnote n="115">¹¹⁵ K.S. Weißmüller, L. De Waele, and A. van Witteloostuijn (2020). ‘Public service motivation and prosocial rule-breaking. An international vignettes study in Belgium, Germany, and the Netherlands’, *Review of Public Personnel Administration*. Online source, retrieved on November 19, 2021, from: https://journals.sagepub.com/doi/full/10.1177/0734371X20973441.</footnote>
success. <fnref n="116" /> Josef Wieland asserts that ethics strengthens the relevancy of organizational activities. Lamis Albdour states that management of internal and external relations and realization of objectives require ethical standards, and that acting in unethical ways is not viable. <fnref n="117" /> Ethics addresses ‘the moral choices (of the individual and the group — GJvB) influenced and guided by values, standards, principles, rules, and strategies associated with organizational activities and business situations.’ It concerns values as fairness, integrity, compassion, honour, and responsibility in structures and behaviours, irrespective of laws and regulations. <fnref n="118" />

<footnote n="116">¹¹⁶ L.R.M. Albdour (2017). ‘Principles of corporate governance and ethics for sustainable business’, *International Journal of Business and Management Invention*, Vol. 6, No. 4, pp. 01–07, p. 01. This may be not the opinion of the top management in many organizations worldwide. In 2011, Milton Friedman’s quote: ‘The social responsibility of business is to increase its profits’ was seen as truth by thirty per cent of top managers in Spain and more than eighty per cent in the United Arab Emirates. In their opinion, profit and the needs of shareholders take precedence over the needs of society or other stakeholders. See: The Economist (2011). ‘Attitudes to business. Milton Friedman goes on tour. A survey of attitudes to business turns up some intriguing national differences’, January 29. Online resource, retrieved on November 19, 2021, from: https://web.archive.org/web/20181119044605/https://www.economist.com/business/2011/01/27/milton-friedman-goes-on-tour.</footnote>

<footnote n="117">¹¹⁷ J. Wieland (2005). ‘Corporate governance, values management, and standards. A European perspective’, *Business and Society*, Vol. 44, No. 1, pp. 74–93, p. 78; Albdour (2017), p. 01. Also: N. Terblanche, L. Pitt, D. Nel, and A. Wallstrom (2008). ‘Corporate governance and business ethics. Pictures of the policies’, *Corporate Ownership and Control*, Vol. 6, No. 2, pp. 246–254.</footnote>

<footnote n="118">¹¹⁸ M.-C. Letendre (2016). ‘Organizational ethics’, H. ten Have (ed.), *Encyclopaedia of Global Bioethics*, Springer, Cham, pp. 2082–2091, pp. 2082–2083 and p. 2086.</footnote>
Organizations need to reach their objectives without harming individuals or society as a whole. <fnref n="119" /> Organizational ethics denotes the responsibilities an individual consents to when becoming part of an organization. The relationship between governance and ethics is all about established trust over time between organizations, their stakeholders, and their environment. <fnref n="120" /> Organizational accountability is (in essence) about monitoring the ethical behaviour of employees to ensure that trust is not (seriously) damaged, that governance can be deemed ‘accountable.’ It is the ‘buttoning up of a company’s collar and the straightening of its tie’, to make clear that ‘good is good, and bad is bad.’ <fnref n="121" /> It encompasses behaviour of the organization in its environment, the relationship with stakeholders, and the monitoring of interactions (in actions, transactions, products, policies, rules, routines, and processes), holding employees ac-

<footnote n="119">¹¹⁹ For a general view of the relationship between organizational ethics and society: B. Tran (2008). ‘Paradigms in corporate ethics. The legality and values of corporate ethics’, *Social Responsibility Journal*, Vol. 4, No. 1-2, pp. 158-171. As note 116 made clear: in business organizations, not everyone is of the same opinion.</footnote>

<footnote n="120">¹²⁰ R. Nainawat, and R. Meena (2013). ‘Corporate governance and business ethics’, *Global Journal of Management and Business Studies*, Vol. 3, No. 10, pp. 1085–1090, p. 1090. Trust as in: [1] *people’s trust*, the trust of organizational governance structures in the people to decide by themselves within a given framework of possible ethical decisions, and [2] *system trust*, trust in the governance structure to provide a useable and acceptable framework for decision-making. R. Müller, S. Erling, Ø. Kvalnes, J. Shao, S. Sankaran, J.R. Turner, C. Biesenthal, D. Walker, S. Gudergan (2013). ‘The interrelationship of governance, trust, and ethics in temporary organizations’, *Project Management Journal*, Vol. 44, No. 4, pp. 26–44, p. 40.</footnote>

<footnote n="121">¹²¹ J. Mizuo (1999). ‘Business ethics and corporate governance in Japanese corporations’, *Business and Society Review*, Vol. 102–103, No. 1, pp. 65–79, p. 66.</footnote>
countable to their stakeholders. Ethics decides what moral principles apply to different situations, and demonstrate goals of fairness, integrity, compassion, honour, and responsibility. <fnref n="122" /> This is (mostly) captured within codes of ethical behaviour. <fnref n="123" />

According to Marie-Catherine Letendre, there are two models for managing organizational ethics. Their codes define how employees should behave, and how they should account for actions. <fnref n="124" /> The first model is *compliance-based* ethics management. When using and implementing this model, organizations intend to find immunity from illegal acts committed by their employees and officials. Maybe just as important for organizational leaders, it reduces pressures for implementation of an integrity-based program that could (or possibly would) be more demanding. The aim of these compliance-based programs is to prevent, detect, and punish activities that violate (external and internal) rules and regulations. They demand ‘strict compliance with administrative procedures and detailed rules (often codified in legislation.)’ <fnref n="125" /> Rules and procedures are prospectively designed and conformity to those rules and procedures is enforced. Compliance-based programs try to enforce good behaviour using external incitements. Ethics based on such compliance is said to be coercion and control oriented, inherently calculative, based on a

<footnote n="122">¹²² Encompasses behaviour: Albdour (2017), p. 04; Ethics decides: Letendre (2016), pp. 2084–2088.</footnote>

<footnote n="123">¹²³ R. Roberts (2009). ‘The rise of compliance-based ethics management. Implications for organizational ethics’, *Public Integrity*, Vol. 11, No. 3, pp. 261–277.</footnote>

<footnote n="124">¹²⁴ Letendre (2016), pp. 2088–2089. See also: M. Philp (2009). ‘Delimiting democratic accountability’, *Political Studies*, Vol. 57, No. 1, pp. 28–53. Letendre’s models correspond with Philp’s distinction between rule- or compliance-based and integrity-based accountability systems.</footnote>

<footnote n="125">¹²⁵ Roberts (2009), p. 262–263.</footnote>
cost-benefit framework, limited in effect, and ethically shallow. <fnref n="126" /> Such an interpretation of ethics and accountability often leads to a systematic use of an existing legal vacuum, leading to immoral or illegal behaviours if the risks are perceived as low. At the same time, distrust towards employees, expressed by sophisticated control and monitoring mechanisms, provokes the behaviour these mechanisms seek to prevent. <fnref n="127" /> It can be perceived as violation of the psychological contract existing between employee and organization, leading to frustration, potentially resulting in immoral or (maybe) illegal behaviour. <fnref n="128" /> Compliance-based programs become self-contradicting when tolerating corruption, incompetence, and mal-administration because the costs of control exceed the benefits. Such a self-contradiction questions its stability and effectiveness and undermines its objective. <fnref n="129" /> In extremis, as John Gardner asserts, such a program could evolve into ‘an ideology of total suspicion’ or ‘total mistrust’ that makes everyone mistrust those ‘whose upstanding-

<footnote n="126">¹²⁶ Control and coercion oriented: G.R. Weaver, L.K. Treviño, and P.L. Cochran (1999). ‘Corporate ethics programs as control systems. Influences of executive commitment and environmental factors’, *Academy of Management Journal*, Vol. 42, No. 1, pp. 41–57, pp. 42–43. Inherently calculative, according to a strategic view: D.A. Waldman, D.S. Siegel, and G.K. Stahl (2020). ‘Defining the socially responsible leader. Revisiting issues in responsible leadership’, *Journal of Leadership & Organizational Studies*, Vol. 27, No. 1, pp. 5–20, p. 5. Ethically shallow: L.S. Paine (1994). ‘Managing for organizational integrity’, *Harvard Business Review*, Vol. 72, No. 2, pp. 106–117.</footnote>

<footnote n="127">¹²⁷ G. Palazzo (2007). ‘Organizational integrity. Understanding the dimensions of ethical and unethical behavior in corporations’, W.C. Zimmerli, K. Richter, and M. Holzinger (eds.), *Corporate Ethics and Corporate Governance*, Berlin–Heidelberg, Springer, pp. 113–128, p. 124.</footnote>

<footnote n="128">¹²⁸ Palazzo (2007), pp. 117–118. Also: Van Bussel (2020), pp. 16–18.</footnote>

<footnote n="129">¹²⁹ Philp (2009), p. 51, note 19.</footnote>
ness the system is meant to secure'.<sup>130</sup> The compliance approach does not leave much room for individual conscience or decision-making (limiting freedom of choice) and does not stimulate employees to deal with ethical issues outside the scope of laws and regulations. The approach has been successful in reducing ‘the level of low-road ethical violations in organizations’, but it cannot guarantee the correctness of individual behaviour in high-level ethical dilemmas. The advantage for organizations is that, if they can convincingly demonstrate to have designed and maintained compliance programs in good faith, it will be possible to avoid severe sanctions and to escape ‘the dilemma of ethical backsliding.’<sup>131</sup> This is what happened in financial institutions before the financial crisis of 2008.

The second model, *integrity-based* ethics management, emphasizes encouragement of good behaviour. Integrity programs are ‘designed to increase human autonomy through aspirational goals avoiding rule structures.’ They focus on what ‘should be achieved rather than what behavior should be avoided.’ They include ‘a focus on what is achieved rather than how it was achieved’, and ‘an emphasis on encouraging good behavior rather than policing and punishing errors or bad behavior.’<sup>132</sup> Organizational ethics based on in-

<footnote n="130"><sup>130</sup> J. Gardner (2006). ‘The mark of responsibility (with a postscript on accountability)’, M.K. Dowdle (ed.), *Public Accountability. Designs, Dilemmas and Experiences*, Cambridge University Press, Cambridge, pp. 220–242, p. 241. For a same view in the context of opportunistic behaviour within organizations: S. Ghoshal, and P. Moran (1996). ‘Bad for practice. A critique of the transaction cost theory’, *Academy of Management Review*, Vol. 21, No. 1, pp. 13–47, pp. 23–25.</footnote>

<footnote n="131"><sup>131</sup> Letendre (2016), pp. 2088; and for citations: p. 2089.</footnote>

<footnote n="132"><sup>132</sup> First citation: S.C. Gilman (2002). ‘Institutions of integrity in the United States’, *Public Sector Transparency and Accountability. Making it Happen*, Paris, OECD, Chapter 3, pp. 17–30, p. 19. Second and third citation: S.</footnote>
tegrity builds upon the values of an organization and its leaders. According to Guido Palazzo, an integrity program is broader than a program guided by compliance, because it builds on, first, ethical principles and, second, its power to influence decision-making. It is assumed that intrinsically motivated employees show more stable behaviour than employees trained to be compliant and threatened by sanctions. 133 Integrity programs, thus, aim for high levels of individual integrity, try to build professional integrity and public trust, and recognize that rules and incentives are not motivational for integrity. Integrity requires that individuals behave appropriately because they are ‘guided by the desire to act in keeping with their responsibilities and fundamental commitments.’ It recognizes that norms and rules have ‘a grip on the mind.’ 134 Integrity programs are difficult to implement and to control. They need the organizational culture to be an ‘ethical culture’ that allows employees to develop ‘ethical sensitivity’, the ability to recognize ethical issues in their work environment. However, even stimulation of ethical sensitivity leaves realization of ethical programs difficult because the cultural background of individual employees is more important for ethical sensitivity than organizational mechanisms for ethical behaviour. 135 An integrity program, ideally, enables responsible be-

<footnote>Washington, and E. Armstrong (1996). *Ethics in the Public Service. Current Issues and Practice*, Paris, OECD, p. 59.</footnote>

<footnote n="133">133 Palazzo (2007), p. 124. Also: Paine (1994).</footnote>

<footnote n="134">134 Citations: Philp (2009), p. 37, and J. Elster (1989). ‘Social norms and economic theory’, *Journal of Economic Perspectives*, Vol. 3, No. 4, pp. 99–117, p. 100.</footnote>

<footnote n="135">135 Ethical culture: S. Webley, and A. Werner (2008). ‘Corporate codes of ethics. Necessary but not sufficient’, *Business Ethics. A European Review*, Vol. 17, No. 4, pp. 405–415, p. 411. Cultural background: M. Fernando, and R.M.M.I. Chowdhury (2010). ‘The relationship between spiritual</footnote>
haviour by becoming the organizational ethos. In daily organiza-
tional life, this ideal image comes close to what Stuart Gilman calls
the biggest risk of this model: ‘wishful thinking.’<sup>136</sup> ECI’s Global
Business Ethics Survey for 2020–2021 confirms this statement. Ac-
cording to this survey: [1] Twenty-nine per cent of employees re-
ported management pressure to bend ethical rules; [2] Eighty per
cent of employees reported (ethical) misconduct; and [3] Sixty-one
per cent of employees experience retaliation after complaining.<sup>137</sup>
Organizational cultures do not seem to be ethical cultures. In addi-
tion, Robert Kaiser and Robert Hogan estimate the base rate for
low integrity managers to be in the ten to twenty per cent range.<sup>138</sup>
This implies that every organization contains a sizable number of
managers capable of sowing mistrust and disengagement among em-
ployees and harming their organizations. It is not startling that
many organizational leaders concentrate on compliance-based eth-
ics management. Integrity-based ethics requires periodical behav-
ioural assessments of the ethical behaviour of employees. Even then,
finding a balance between ‘hard’ compliance and ‘soft’ integrity is a
challenge for organizational governance,<sup>139</sup> just like finding a bal-
ance between collective and individual accountability.

<footnote>well-being and ethical orientations in decision making. An empirical study
with business executives in Australia', *Journal of Business Ethics*, Vol. 95,
No. 2, pp. 211-225, pp. 221-222.</footnote>

<footnote n="136">¹³⁶ Gilman (2002), p. 19.</footnote>

<footnote n="137">¹³⁷ ECI (2021). *The State of Ethics & Compliance in the Workplace. A Look at Global Trends. Global Business Ethics Survey, 2020-2021*, ECI, Frankfurt.</footnote>

<footnote n="138">¹³⁸ R.B. Kaiser, and J. Hogan (2010). ‘How to (and how not to) assess the integrity of managers’, *Consulting Psychology Journal. Practice and Research*, Vol. 62, No. 4, 216–234, p. 231.</footnote>

<footnote n="139">¹³⁹ B.H. Geddes (2017). ‘Integrity or compliance-based ethics. Which is better for today’s business?’, *Open Journal of Business and Management*, Vol. 5, No. 3, pp. 420–429.</footnote>
The behaviour of financial institutions and governments in and
before the ‘Great Recession’ and the large amount of organizational
scandals in the last decades have undermined trust in (big) organiza-
tions. <fnref n="140" /> There are many reasons for concern about their social im-
pact. Thomas Friedman believes that because of globalization most
multinationals increasingly influence society. Because of their in-
vestments in countries in which they operate, they are replacing
public institutions more and more. <fnref n="141" /> This idea was not new: in
1998, Mark Bovens elaborated on the growing impact of business
organizations in social and political life: ‘a number of corporate
risks have such enormous consequences that their prevention read-
ily becomes a centrally important matter of public interest.’ <fnref n="142" />

Financial multinationals, especially, are becoming ‘too-big-to-
fail.’ <fnref n="143" /> Most of these (big) organizations do have an independent
legal status and, as such, can legally be held accountable as a unitary

<footnote n="140">¹⁴⁰ For the corporate scandals in the U.S.A.: J.W. Markham (2015). *A Financial History of Modern US Corporate Scandals. From Enron to Reform*, Routledge, Abingdon-New York.</footnote>

<footnote n="141">¹⁴¹ T. Friedman (2005). *The World is Flat. A Brief History of the Twenty-first Century*, Farrar, Straus and Giroux, New York (second revised and expanded edition).</footnote>

<footnote n="142">¹⁴² M. Bovens (1998). *The Quest for Responsibility. Accountability and Citizenship in Complex Organisations*, Cambridge University Press, Cambridge, p. 169.</footnote>

<footnote n="143">¹⁴³ P. Molyneux (2016). ‘Structural reform, too-big-to-fail and banks as public utilities in Europe’, S.P.S. Rossi, and R. Malavasi (eds.), *Financial Crisis, Bank Behaviour and Credit Crunch*, Springer, Berlin, Chapter 5, pp. 67–80.</footnote>
actor. Such a collectivist view is a way to circumnavigate issues of identification of accountable actors within organizations. As a result, every member of that organization can be held personally accountable for the behaviour of that organization as a whole. This view is based on the idea that the identity of a collective (such as an organization) is more than the sum of the identities of its individual members. The assumption is that this identity is not directly modified when a collective's membership changes. Bovens states that 'the conduct of an organization is often the result of interplay between fatherless traditions and orphaned decisions', traditions that nobody knows the origins of, and decisions worked on by many employees no longer there. It is identified as the 'problem of many hands.' <fnref n="144" />

This collectivist approach is based on the (disputed) assumption that an organization can be a moral agent, just like an individual. It is, after all, not easy to unravel chains of authority to identify the individuals accountable for a decision. It is an interesting philosophical question, but its practical implications are, in my opinion, limited. <fnref n="145" /> Organizations are (moral agents, or not) still responsible,

<footnote n="144">¹⁴⁴ Citation: M. Bovens (2007a). 'Analysing and assessing accountability. A conceptual framework', *European Law Journal*, Vol. 13, No. 4, pp. 447–468, p. 458. 'Many hands': D.F. Thompson (2017). 'Designing responsibility. The problem of many hands in complex organizations', J. van den Hoven, S. Miller, and T. Pogge (eds.), *The Design Turn in Applied Ethics*, Oxford University Press, Oxford, pp. 32–56. Thompson introduced this problem in: D.F. Thompson (1980). 'Moral responsibility of public officials. The problem of many hands', *American Political Science Review*, Vol. 74, No. 4, pp. 905–915.</footnote>

<footnote n="145">¹⁴⁵ M. Smiley (2020). ‘Collective Responsibility’, E.N. Zalta (ed.), *The Stanford Encyclopedia of Philosophy*, The Metaphysics Research Lab, Center for the Study of Language and Information (CSLI), Stanford University, Stanford, Spring 2020 Edition. Online source, retrieved on November 19, 2021,</footnote>
can legally be fined, and their behaviour can publicly and legally be
condemned. Individual employees will still need to account for con-
sequences of organizational misbehaviour, and individual organiza-
tional leaders will still have to respond. There is *always* an individ-
ual dimension.

The individualist approach states that an individual employee as
a moral agent is accountable for the outcomes of transactions inso-
far as the outcome is caused by an individual’s actions or omissions,
and the actions or omissions are not done in ignorance or under
compulsion. <fnref n="146" /> In this view, an employee (may (s)he be a leader or
not) is individually and proportionally held accountable (and even
liable) for his/her contributions to organizational behaviour. Em-
ployees are judged based on actual contributions instead of formal
positions. It makes it impossible for them to hide behind their or-
ganization, while at the same time those in charge do not have to
shoulder all the blame. <fnref n="147" /> But the ‘problem of many hands’ still
persists, because the consequences of individual acts or omissions
are in reality often out of proportion to the effects of organizational
behaviour. The financial crisis, for instance, is beyond anything an
individual may have done or may be held accountable for. The er-
rors of individuals, how contemptible they may be, pale in compar-
ison with the (potential) damage done by an organization. <fnref n="148" />

Although from an ethical point of view the individual approach
for accountability is preferable, it does not solve the accountability
problem for the collective consequences of organizational misbe-
haviour. This does not mean it is not necessary to find those individ-

from: https://plato.stanford.edu/archives/spr2020/entries/collective-responsibility/.

<footnote n="146">¹⁴⁶ Thompson (2017), p. 33.</footnote>

<footnote n="147">¹⁴⁷ Bovens (2007a), p. 459.</footnote>

<footnote n="148">¹⁴⁸ Thompson (2017), pp. 33–35.</footnote>
ual employees accountable for specific actions, but a collective approach is unavoidable for organizational behaviour that results in damages that cannot be explained by separate acts of individuals. Such damages may be more common in complex organizations than might be expected.

## FINDING EQUILIBRIA

********

Organizational governance needs to find equilibria between performance and accountability, between compliance and integrity, and between a collective and an individual approach. Emmanuel Yeboah-Assiamah, concentrating on corruption control, thinks a balanced approach of strong personalities (officials with integrity and personal ethics), strong organizations (organizations adopting, enforcing and monitoring appropriate systems), and a strong third force (tough outside actors mediating between strong personalities and strong organizations to compel them to order), is needed. <fnref n="149" /> Organizational governance requires a concerted effort from organizational personalities, the organization, and external actors that are strong enough to hold the organization (and the individuals in it) accountable. Needed is a deliberate and careful strategy to communicate accountable governance to all employees. Incorporation of business ethics in interactions, existing strategies, rules, systems, processes, and internal communication efforts will help in assisting and evaluating employees in applying ethical and compliance rules

<footnote n="149">¹⁴⁹ E. Yeboah-Assiamah (2017). ‘Strong personalities’ and ‘strong institutions’ mediated by a ‘strong third force.’ Thinking ‘systems’ in corruption control’, *Public Organization Review*, Vol. 17, No. 4, pp. 545–562.</footnote>
in practice. <fnref n="150" /> According to Thompson, internal ‘oversight bodies ... could be charged with holding individuals in the organization responsible on a continuing basis, and most importantly with exposing organizational defects that obstruct individual responsibility.’ <fnref n="151" /> They would force organizations to design accountable governance.

For all these dilemmas for accountable governance (performance and accountability, compliance and integrity, and collective and individual approaches) a very complicated ‘can of worms’ should be addressed: what about the ethical consequences of algorithmically-driven decision-making in organizational business processes? As Kirsten Martin stated, scholars are arguing as to how algorithms can and should be transparent in order to be governed, including (more) autonomous algorithms such as machine learning, artificial intelligence, and neural networks. Organizations that use such ‘black boxes’ in their business processes *are* accountable for their acts and consequences even when they claim algorithms are complicated and difficult to understand. <fnref n="152" /> The use of algorithms does have ethical implications, enables or diminishes stakeholder rights, and influences the delegation of roles and responsibilities within organizational decision-making. There is no doubt about neutral algorithms: they do *not exist*, and as such it should be clear who is accountable for the consequences of value-laden algorithms. <fnref n="153" /> When it is not clear

<footnote n="150">¹⁵⁰ A.W.H. Chan, and H.Y. Cheung (2012). ‘Cultural dimensions, ethical sensitivity, and corporate governance’, *Journal of Business Ethics*, Vol. 110, pp. 45–59, p. 46–48.</footnote>

<footnote n="151">¹⁵¹ Thompson (2017), p. 52.</footnote>

<footnote n="152">¹⁵² K.E. Martin (2019). ‘Ethical implications and accountability of algorithms’, *Journal of Business Ethics*, Vol. 160, No. 4, pp. 835–850, p. 837.</footnote>

<footnote n="153">¹⁵³ B.D. Mittelstadt, P. Allo, M. Taddeo, S. Wachter, and L. Floridi (2016). ‘The ethics of algorithms. Mapping the debate’, *Big Data & Society*, Vol. 3,</footnote>
whether used algorithms are in accordance with laws and regula-
tions, the ethical codes and the defined business processes of the or-
ganization that uses them, the developer of the algorithm should be
accountable for their (ethical) consequences. This should be part of
all agreements, contracts, and service level agreements with all soft-
ware developers that offer solutions based on decision-making al-
gorithms. For accountable governance, organizational leaders need
to ascertain that algorithmic accountability is embedded within in-
formation governance structures and strategies.

<footnote>No. 2, pp. 1–21, p. 1; A. Caliska, J.J. Bryson, and A. Narayanan (2017). ‘Semantics derived automatically from language corpora necessarily contain human biases’, *Science*, Vol. 356, No. 6334, pp. 183–186, and F. Kraemer, K. van Overveld, and M. Peterson (2011). ‘Is there an ethics of algorithms?’, *Ethics and Information Technology*, Vol. 13, pp. 251–260.</footnote>
2

# THE ACCOUNTABILITY CONCEPT

*
The external expectations of organizational accountability force organizational leaders to find solutions and answers in organizational (and information) governance to assuage the feelings of doubt and unease about the behaviour of the organization and its employees that continuously seem to be expressed in the organizational environment. Organizational leaders have to align the interests of their share- and stakeholders in finding a balance between performance and accountability, individual and collective ethical approaches, and business ethics based on compliance, based on integrity, or both. They have to integrate accountability in organizational governance based on a strategy that defines boundaries for rules and routines. They need to define authority structures and find ways to control the behaviour of their employees, without being very restrictive and coercive. They have to implement accountability structures in organizational interactions that are extremely complex, nonlinear, and dynamic, in which (mostly informal) relational networks of employees traverse formal structures. Formal processes, rules, and regulations, used for control and compliance, cannot handle such environments, continuously in ‘social flux’, unpredictable, unstable, and (largely) unmanageable.<fnref n="154" /> It is a challenging task that asks exceptional management skills from organizational leaders. The external expectations of accountability cannot be neglected, even if it is not always clear what is exactly meant with that concept. Why is this (very old) concept still of importance for modern organizations?

<footnote n="154">¹⁵⁴ Van Bussel (2020), p. 88.</footnote>
A WORD AND A CONCEPT

********

Melvin Dubnick states that the linking of the *word* 'accountability' to its modern conceptualization can be traced to the reign of William I the Conqueror, but that the *concept* itself can be traced back to ancient roots in record-keeping activities related to governance and money-lending systems. Even in the eleventh century, the *concept* had been there for a long time, although the etymology of the *word* does not mirror that history. <fnref n="155" />

The *word* accountability does not appear in English until its use
in thirteenth century England in relationship to the sovereign pow-
er of the king, especially the necessity of giving the king an account
of one's conduct. <fnref n="156" /> This meaning of 'being accountable' ('accompt-
able') for the *word* accountability became dominant from the mid-
dle of the fifteenth century onwards but, as Dubnick asserted, the
*concept* can be traced back to the eleventh century, and long before,
even if a term is used with overlapping meaning (for instance, re-
sponsibility) or there is only a contextual description. <fnref n="157" /> The lin-

<footnote n="155">¹⁵⁵ Dubnick (2002), pp. 3, 7–8. See also: C.O. Omodero (2019). ‘Genesis of accountability and its impact on accounting’, *International Journal of Financial, Accounting, and Management*, Vol. 1, No. 1, pp. 47–55.</footnote>

<footnote n="156">¹⁵⁶ G.I. Seidman (2005). ‘The origins of accountability. Everything I know about the sovereign’s immunity, I learned from king Henry III’, *St. Louis University Law Journal*, Vol. 49, No. 2, pp. 393–480.</footnote>

<footnote n="157">¹⁵⁷ S.K. McGrath, and S.J. Whitty (2018). ‘Accountability and responsibility defined’, *International Journal of Managing Projects in Business*, Vol. 11, No. 3, pp. 687–707, p. 697, assert that there is an overlap in meaning between responsibility and accountability and that only in the middle of the seventeenth century there was ‘divergence of meaning’, gradually establishing non-overlapping concepts.</footnote>
guistical root of the *word* is in the Late Latin verb ‘accomptare’ and
is related to accounting, in its literal sense of bookkeeping. <fnref n="158" /> The
meaning of the *word*, ‘being accountable’, means the behaviour of
account-giving, producing ‘a count’ of properties or money held in
care, referring to both the *capacity* of an individual, and his or her
*obligation* to produce an account. <fnref n="159" />

According to Dubnick and Justice's analysis of scholarly litera-
ture, accountability as a *concept* emerges in *at least* six interrelated
contexts: a cultural, institutional, transactional, organizational, task
environmental, and social psychological context. In each of these
frames, the conceptualization of accountability seems to be differ-
ent. Dubnick and Justice consider these different conceptualizations
to be 'family resemblances.' <fnref n="160" /> Such conceptualizations exist, ac-
cording to Ludwig Wittgenstein, by virtue of 'resemblances' rather
than by virtue of a set of necessary and sufficient properties. <fnref n="161" /> Witt-
genstein's theory was that such a concept has an open-ended set of
identifying features, implying that not all of these features are nec-
essary for the concept to apply. Wittgenstein rejects the traditional
view that there is one, essential core in which the meaning of a word
is located and is common to all uses of that word. He wants philos-
ophers to travel with the uses of words through 'a complicated net-

<footnote n="158">¹⁵⁸ Omodero (2019), p. 48. ‘Accomptare’, to account, a prefixed form of ‘computare’, to count or calculate, which is derived from ‘putare’, to reckon. The Old French development of ‘accomptare’, ‘comptes a rendre’, is source for the Middle English terms ‘acompte’ and ‘aconte’. Dubnick, and Justice (2004), pp. 6–7.</footnote>

<footnote n="159">¹⁵⁹ D. Castiglione (2007). ‘Accountability’, M. Bevin (ed.), *Encyclopedia of Governance*. Volume I, A–J, SAGE, Thousand Oaks, pp. 1–7, p. 1.</footnote>

<footnote n="160">¹⁶⁰ Dubnick, and Justice (2004), pp. 9–11.</footnote>

<footnote n="161">¹⁶¹ L. Wittgenstein (2009). *Philosophical Investigations*, John Wiley & Sons, Chicago (fourth edition), § 65–67, pp. 35–37.</footnote>
work of similarities overlapping and criss-crossing: similarities in
the large and in the small.’<fnref n="162" />

There are philosophical problems with the ‘family resemblance’
idea. One of them is that concepts can be classified in many general
classes based on their resemblance, even in such a way that a concept
would become vacuous, since it does not exclude anything. <fnref n="163" /> Mi-
chael Forster states, in addition, that it may be difficult to tell if
people are using genuine concepts at all, although if multiple indi-
viduals apply a concept in agreement with each other, that problem
would be more of less solved, although, I may add, not philosophi-
cally. <fnref n="164" /> ‘Family resemblance’ has, nevertheless, been used as a way
to explain scientific, cultural, and societal phenomena. <fnref n="165" />

<footnote n="162">¹⁶² Citations: Wittgenstein (2009), § 66, p. 36. About Wittgenstein’s theory about ‘family resemblance’: A. Biletzki, and A. Matar (2020). ‘Ludwig Wittgenstein’, E.N. Zalta (ed.) *The Stanford Encyclopedia of Philosophy*, The Metaphysics Research Lab, Center for the Study of Language and Information (CSLI), Stanford University, Stanford, Spring 2020 Edition. Online source, retrieved on November 19, 2021, from: https://plato.stanford.edu/archives/spr2020/entries/wittgenstein/.</footnote>

<footnote n="163">¹⁶³ L. Pompa (1967). 'Family resemblance', *The Philosophical Quarterly*, Vol. 17, No. 66, pp. 63–69, p. 65.</footnote>

<footnote n="164">¹⁶⁴ M. Forster (2010). ‘Wittgenstein on family resemblance concepts’, A. Ahmed (ed.), *Wittgenstein’s Philosophical Investigations. A Critical Guide*, Cambridge University Press, New York, pp. 66-87, pp. 83-84. Forster describes the existing problems with ‘family resemblance.’ See: pp. 81-85.</footnote>

<footnote n="165">¹⁶⁵ Examples: T. Kuhn (2012). *The Structure of Scientific Revolutions*, University of Chicago Press, Chicago (fourth (anniversary) edition), p. 45–46 (on scientific paradigms); E. Rosch (1987). ‘Wittgenstein and categorization research in cognitive psychology’, M. Chapman, and R. Dixon (eds.), *Meaning and the Growth of Understanding. Wittgenstein’s Significance for Developmental Psychology*, Erlbaum, Hillsdale (NJ) (in cognitive psychology.)</footnote>
There may be a different understanding of the *concept* accountability, they all are, however, related to the meaning of the *word*: 'being accountable', but with different definitions and (possibly) different properties. As the conceptualizations of accountability, recognized by Dubnick and Justice, share the core meaning of the word: 'being accountable', it is questionable if they show 'family resemblance.' They may have different definitions or properties, they may even have open-ended sets of properties, but they all share one, essential core of meaning that identifies them, in essence, as one concept used in different contexts.<fnref n="166" /> It is without doubt that accountability was (and is) part of a group of concepts covering interrelated meanings regarding political representation, administrative responsibility, and legal liability (like responsibility or answerability). Most of those concepts do each have an essential core of meaning, making it questionable they belong to a 'family resemblance,' although it is possible that they were in the past.<fnref n="167" /> I agree with Dubnick and Justice when they state the concept is associated with governance activities and that it is 'a characteristic of governance' in environments where there is 'a sense of agreement about the legitimacy of expectations'. It depends 'on the dynamic social interac-

<footnote n="166">¹⁶⁶ Lindberg (2013), pp. 207–208, states clearly that accountability has an *essential* core of meaning for which a specific set of properties or characteristics is necessary. There may be extra characteristics in the different contexts in which the concept is used, but without this core set of properties the concept does not exist.</footnote>

<footnote n="167">¹⁶⁷ McGrath, and Whitty (2018) state that an identifying meaning for accountability' and 'responsibility' developed in the middle of the seventeenth century. It is possible that it shared 'family resemblance' with responsibility before both concepts developed identifying meaning. According to O'Kelly, and Dubnick (2019), p. 49, accountability is often regarded as a species of 'responsibility'.</footnote>
tions and mechanisms created' within such an environment. <fnref n="168" /> I
consider accountability to be one of the objectives of organizational
governance. Those 'dynamic social interactions', I may add, are al-
ways concentrated on 'being accountable', rendering an account of
one's behaviour to another party.

ACCOUNTABILITY: A SHORT HISTORY

********

Interpreting the concept as an objective of governance and as
'social interactions and mechanisms' concentrated on 'being ac-
countable', makes writing a history of accountability easier, because
mechanisms similar to those of today's systems of accountability
can be found in old Mesopotamia, before spreading to Egypt, My-
cenae, and the Persian Empire, continuing through the Hellenistic,
Seleucid and Roman periods. <fnref n="169" /> During Roman times, governors,

<footnote n="168">¹⁶⁸ Dubnick, and Justice (2004), p. 11–12.</footnote>

<footnote n="169">¹⁶⁹ M. Brosius (2003). 'Ancient archives. An introduction', M. Brosius (ed.), *Ancient Archives and Archival Traditions. Concepts of Record-Keeping in the Ancient World*, Oxford University Press, Oxford, pp. 1-16. For Mesopotamia and Egypt: S. Carmona, M. Ezzamel (2007). 'Accounting and accountability in ancient civilizations. Mesopotamia and ancient Egypt', *Accounting, Auditing & Accountability Journal*, Vol. 20, No. 2, pp. 177-209, and M. Ezzamel (1997). 'Accounting, control and accountability. Preliminary evidence from ancient Egypt', *Critical Perspectives on Accounting*, Vol. 8, No. 6, pp. 563-601. For ancient Greece: J. Elster (1999). 'Accountability in Athenian politics', A. Przeworski, S.C. Stokes, and B. Manin (eds.), *Democracy, Accountability, and Representation*, Oxford University Press, Oxford, pp. 253-278. For ancient Persia: M. Waters (2014), 'Mechanics of empire', M. Waters, *Ancient Persia. A Concise History of the Aechemenid Empire*, 550-330 BCE, Cambridge University Press, New York, pp. 92-113.</footnote>
officials, and municipalities were obliged to keep *commentarii* or
daybooks of official activity as well as annual accounts (*annuarii*).
These were all inspected by higher authorities that marked each en-
try as being read. All these accounts were publicly displayed, open
for inspection by interested parties even after they had been taken
over by the head of the records office. <fnref n="170" /> Cato Minor (of Utica)
took steps to prevent fraud by ensuring that financial activities were
recorded accurately and inspected regularly, even if access proved
difficult. <fnref n="171" /> The eastern part of the Roman Empire, evolving into
the Byzantine Empire in the fourth century, retained the authority
and accountability structures of the Romans and developed them to
serve the administrative and authority needs of an empire extending
throughout the Mediterranean world and southern Europe. <fnref n="172" /> Dur-

<footnote>For an overview of Greece, Rome, and Byzantium: D. Argyriades (1998).
‘Administrative legacies of Greece, Rome, and Byzantium’, *International Journal of Public Administration*, Vol. 21, No. 1, pp. 109–126. Interesting
are paragraphs 229, 232, and 233 of Hammurabi’s code concerning account-
ability for entrepreneurs. See: R.F. Harper (1904). *The Code of Hammurabi,
King, of Babylon about 2250 B.C.*, University of Chicago Press, Chicago, pp.
81–83. Online source, retrieved on November 19, 2021, from:
https://oll.libertyfund.org/titles/hammurabi-the-code-of-hammurabi. Ac-
countability was also common in ancient China. See: M. Brown, and Y.
Xie (2015). ‘Between heaven and earth. Dual accountability in Han China’,
*Chinese Journal of Sociology*, Vol. 1, No. 1, pp. 56–87.</footnote>

<footnote n="170">¹⁷⁰ E. Posner (2003). *Archives in the Ancient World*, Society of American Archivists, Chicago (second edition), pp. 139–141.</footnote>

<footnote n="171">¹⁷¹ E.N. Gladden (1972). *A History of Public Administration*, Frank Cass, London, Vol I, pp. 257–258. About the problems of access: P. Culham (1989). ‘Archives and alternatives in Republican Rome’, *Classical Philology*, Vol. 84, No. 2, pp. 100–115, p. 113.</footnote>

<footnote n="172">¹⁷² C.R. Baker (2013). ‘Administrative and accounting practices in the Byzantine Empire’, *Accounting History*, Vol. 18, No. 2, pp. 211–227.</footnote>
ing the emergence of ‘the barbarian west’, as John Wallace-Hadrill
called the transformational age following the decline of the Western
Roman Empire,<fnref n="173" /> the evidence about authority and accountability
structures is diverse: from (1) ‘administrative dualism’ and ‘rejuve-
nation of Rome’ in the Ostrogoth kingdom of Theodric the Great;
(2) the Visigothic code that gathered everyone under the same (Ro-
man evolved) jurisdiction; to (3) the largely unknown authority and
accountability structures of the Merovingians (almost certainly tied
firmly to the written word.) <fnref n="174" /> Charlemagne, in the eight century,
build on a long tradition by requiring the use of written administra-
tive documents, for memory, evidence, and accountability. <fnref n="175" /> The
Frankish king exercised authority over his territories by sending
correspondence and instructions and asking for and receiving re-
ports back. His *missi dominici* (palace inspectors) supervised local

<footnote n="173">¹⁷³ J.M. Wallace-Hadrill (1962). *The Barbarian West. The Early Middle Ages, A.D. 400-1000*, Hutchinson & Co, London (second edition). Since Wallace-Hadrill wrote his much-cited book, scholars minimize the part of the ‘barbarians’ in the fall of the Roman Empire and view them more as ‘will-ing participants’ in extending its rule and civilization. See: W. Goffart (2006). *Barbarian Tides. The Migration Age and the Later Roman Empire*, University of Philadelphia Press, Philadelphia, chapter 8, pp. 230-239.</footnote>

<footnote n="174">¹⁷⁴ J.J. Arnold (2014). *Theoderic and the Roman Imperial Restoration*, Cambridge University Press, New York, following Goffart’s thesis; J.H.W.G. Liebeschuetz (2014). ‘Goths and Romans in the leges visigothorum’, G. de Kleijn and S. Benoist (eds.), *Integration in Rome and in the Roman World. Proceedings of the Tenth Workshop of the International Network Impact of Empire (Lille, June 23–25, 2011)*, Brill, Leiden, pp. 89–104. For the Merovingians: I. Wood (1990). ‘Administration, law and culture in Merovingian Gaul’, R. McKitterick (ed.), *The Uses of Literacy in Early Mediaeval Europe*, Cambridge University Press, Cambridge-New York, pp. 63–81.</footnote>

<footnote n="175">¹⁷⁵ R. McKitterick (1989). *The Carolingians and the Written Word*, Cambridge University Press, Cambridge, pp. 25-37.</footnote>
administrations as intermediaries between the king and the counts, his administrative delegates. One of the preliminaries in building a more centralized Carolingian government were the registrations of the property of the king's vassals and the Crown itself, an administrative method often used afterwards in building nation states. <fnref n="176" />

The roots of the modern nation states, in which accountability was to become a centralizing force, can be found in the changes in the last half of the eleventh century when economic growth, political fragmentation, and European expansion resulted in tumult, new political constellations and/or systems, and the slow emergence of centralized authority. <fnref n="177" /> Rulers in Sicily and Britain found the need to develop mechanisms that formed the rudimentary basis for modern government structures. The Norman conquests of Sicily and Britain, followed by their attempts to consolidate their kingships in a government system where considerable power rested with local lords, are examples of the emerging new political constellations. In Sicily, a centralized government was built by retaining the existing

<footnote n="176">¹⁷⁶ McKitterick (1989), pp. 27–30. See also: J.R. Davis (2015). *Charlemagne’s Practice of Empire*, Cambridge University Press, Cambridge, especially chapter 2, pp. 90–127, which recognizes the counts as ‘accountable agents’ and the king’s boundaries in enforcing accountability.</footnote>

<footnote n="177">¹⁷⁷ J.R.S. Phillips (1998). ‘Europe in the eleventh century’, J.R.S. Phillips, *The Medieval Expansion of Europe*, Oxford University Press, Oxford, New York (second edition), Chapter 2, pp. 17–23. For the development of politics and law: H.J. Berman (1983). ‘The origin of the Western legal tradition in the Papal Revolution’, H.J. Berman, *Law and Revolution. The Formation of the Western Legal Tradition*, I, Harvard University Press, Cambridge (Ms.), pp. 85–119. For economic growth: J.L. van Zanden (2009). ‘Why the European economy expanded rapidly in a period of political fragmentation’, J.L. van Zanden (ed.), *The Long Road to the Industrial Revolution. The European Economy in a Global Perspective, 1000–1800*, E.J. Brill, Leiden, chapter 2, pp. 32–68.</footnote>
administrative methods, instruments, and accountability structures
from the preceding Byzantine and Muslim government traditions.
The most important instrument for realizing a centralized govern-
ment in Sicily was the land register, which was strictly controlled
and revised. This became an important task for the emerging central
government. <fnref n="178" /> By 1086, in Britain, William I the Conqueror could
assert his claim to the English realm in commissioning the Domes-
day census, in which every subject (not only those hierarchically
immediately below him) was required to provide access to royal au-
ditors for the listing and valuation of holdings, much alike the prac-
tices in Sicily. It is argued that the Domesday census had primarily
an accounting function, although it served many purposes. It was
used to revise tax assessments, served as an aid for decision-making
and for controlling the aristocracy, and, last but not least, it was a
source of information to solve land disputes. It became a centraliz-
ing force as an instrument for accountability and decision-making.
All subjects received the message that the conquest was complete
and a new authority was in place. <fnref n="179" /> In that same year, William I
visited Salisbury, where all landowners swore oaths of allegiance, as
a ‘performative enactment’ of governance through ‘the creation of
a moral community based on sworn oaths of obedience.’ <fnref n="180" /> These
oaths were the first enactment of accountability as foundation for a
nation state. Henry I (1100–1135) established a centralized admini-
stration where auditing and semi-annual account-giving mecha-
nisms replaced armed force. By the 1130s, a centralized rule was es-

<footnote n="178">¹⁷⁸ H. Takayama (1993). *The Administration of the Norman Kingdom of Sicily*, E.J. Brill, Leiden, New York, pp. 25–46.</footnote>

<footnote n="179">¹⁷⁹ A. Godfrey, and K. Hooper (1996). ‘Accountability and decision-making in feudal England. Domesday Book revisited’, *Accounting History*, Vol. 1, No. 1, pp. 35–54.</footnote>

<footnote n="180">¹⁸⁰ Dubnick (2002), p. 8.</footnote>
tablished in which accountability was very important. <fnref n="181" /> The administrative system tied local authority to the centre by continuously strengthening the existing accountability methods. <fnref n="182" /> The development from ‘auditing of accounts’ to ‘institutional accountability’, thus, can be dated from the twelfth to the fourteenth century.

The use of the accountability concept is born of conquest, sustained by force, and established on commitments and contracts that provided a rule of law. <fnref n="183" /> From then on, the history of the accountability concept followed the development of nation states and sovereign authority, until, at the end of the twentieth century, it became ‘a malleable and often nebulous concept, with connotations that change with the context and agenda.’ <fnref n="184" />

## ASSUMPTIONS AND BARRIERS

********

The transformation of the concept into a much broader form made accountability into an ambiguous buzzword, because of its assumed close relationship with transparency. <fnref n="185" /> Many of the ‘af-

<footnote n="181">¹⁸¹ C.W. Hollister (2001). *Henry I*. Yale University Press, New Haven and London, Chapter 5, pp. 204–233.</footnote>

<footnote n="182">¹⁸² Dubnick (2002), p. 9.</footnote>

<footnote n="183">¹⁸³ Dubnick (2002), p. 10.</footnote>

<footnote n="184">¹⁸⁴ Citation: P. Newell, and S. Bellour (2002). *Mapping Accountability. Origins, Contexts and Implications for Development*, IDS Working Paper 168, Institute of Development Studies, Sussex, p. 2; C. Harlow (2002). *Accountability in the European Union*, Oxford University Press, Oxford, p. 19.</footnote>

<footnote n="185">¹⁸⁵ J. Rubenstein (2007). ‘Accountability in an unequal world’, *The Journal of Politics*, Vol. 69, No. 3, p. 616–632. On p. 20, she states that: ‘accountability is often treated as a buzzword that is good in and of itself.’</footnote>
ter-financial-crisis' rules and regulations are about increasing trans-
parency, assuming that more (and better) information will allow for
better accountability for policies and performance. <fnref n="186" /> This link
seems obvious: without information about policies, decisions, prod-
ucts, actions, and transactions, accountability will be difficult. In
reality, it is not that straightforward. Jonathan Fox, for instance,
states that ‘the terms transparency and accountability are both quite
malleable and therefore — conveniently — can mean all things to all
people.’ Fox emphasizes that the more relevant question is: ‘what
kinds of transparency lead to what kinds of accountability, and un-
der what conditions?’ <fnref n="187" /> Christopher Hood emphasized that the re-
lationship is contextual, that it depends on the way the environment
of that relationship is envisioned. Using an *egalitarian* worldview,
both concepts would be ‘Siamese twins’; when using an *individual*
worldview (most often implied in literature and, nowadays, the
most politically desirable) it would be ‘matching parts.’ <fnref n="188" /> Defini-

<footnote n="186">¹⁸⁶ In a review of literature, it is emphasized that public access to informa-
tion is extremely important for accountability: D. Kaufmann, and A. Bell-
ver (2005). *Transparenting Transparency. Initial Empirics and Policy Appli-
cations*, MPRA Paper 8188, University Library of Munich, Munich, pp.
5–14. Online source, retrieved on November 19, 2021, from:
https://mpra.ub.uni-muenchen.de/8188/1/MPRA_paper_8188.pdf.</footnote>

<footnote n="187">¹⁸⁷ J. Fox (2007). ‘The uncertain relationship between transparency and accountability’, *Development in Practice*, Vol. 17, No. 4–5, pp. 663–671, p. 663.</footnote>

<footnote n="188">¹⁸⁸ Hood agrees with Fox about the uncertainty of the relationship. C. Hood (2010). ‘Accountability and transparency. Siamese twins, matching parts, awkward couple?’, *West European Politics*, Vol. 33, No. 5, pp. 989–1009, especially pp. 993–998. See for a similar view: D. Wyatt (2018). *The Many Dimensions of Transparency. A Literature Review*. Helsinki Legal Studies Research Paper, No. 53. Online source, retrieved on November 19, 2021, from: https://ssrn.com/abstract=3213821.</footnote>
tions depend on who demands them, which determines their imple-
mentation and how they affect each other. The relationship be-
tween transparency, accountability and information disclosure as
concepts is also not without problems. That relationship can be
‘clear’, but it can also be very ‘opaque’ when more information does
not mean ‘better’ transparency and/or ‘better’ accountability. <sup>189</sup> In
information governance, this relationship has to be evaluated in
such a way that a translation is made to the information needed for
transparency as well as accountability.

The ‘after-financial-crisis’ regulatory strategy, mentioned be-
fore, is not only based on assumptions about (informational) trans-
parency, although this one is the most widespread in public opin-
ion. More than ten years ago, in her work about accountability in a
‘network society’, Mollie Painter-Morland explained that there are
also other (questionable) assumptions about organizational account-
ability. The first assumption is that there is a cause-and-effect rela-
tionship between organizational decisions and subsequent (nega-
tive) consequences. The second assumption mentioned by Painter-
Morland is that decisions (and following actions) are rational and
deliberate, and that decision-makers do have an objective concep-
tion of the ‘right’ thing to do. A third assumption is that stricter
rules realize better control over the actions and decisions of employ-
ees and that fear of punishment prevents misconduct. <sup>190</sup>

All assumptions are based on simplifications of reality. Organi-
zational situations are side effects of multidirectional interactions of

<footnote n="189">¹⁸⁹ K. Dingwerth, and M. Eichinger (2010). ‘Tamed transparency. How in-
formation disclosure under the Global Reporting Initiative fails to em-
power’, *Global Environmental Politics*, Vol. 10, No. 3, pp. 74–96.</footnote>

<footnote n="190">¹⁹⁰ M. Painter-Morland (2007a). ‘Defining accountability in a network so-
ciety’, *Business Ethics Quarterly*, Vol. 17, No. 3, pp. 515–534, p. 516.</footnote>
many diverse actors. <fnref n="191" /> Both the dynamics of these interactions and the erratic strategic decisions by managers when coping with hostile and dynamic environments, determine rationality and significance of decisions. <fnref n="192" /> Decisions are influenced by managerial perceptions of the (regulatory) environment, based on psychological and relational climates within organizations, and organizational culture. Impartial decision-makers that act rationally do not exist. <fnref n="193" /> As we have seen before, even the relationship between regulatory rules and behavioural compliance is an unproven assumption. The social norms, the rules shared, controlled and sanctioned within the relational climate of a work group, team, or place of work, will influence responses to regulatory policies. Such responses could evoke ‘feelings of duty’ to comply with legal rules, but they could also favour non-compliance. It is, therefore, questionable if new regulations really address accountability failures in organizations. <fnref n="194" />

Another assumption could prove even more daunting: the assumption — especially prevalent in legislative circles — that (infor-

<footnote n="191">¹⁹¹ D. Ford, L.-E. Gadde, H. Håkansson, I. Snehota, and A. Waluszewski (2010). ‘Analysing business interaction’, *IMP Journal*, Vol. 4, No. 1, pp. 82–103, pp. 82–85. Online source, retrieved on November 19, 2021, from: http://www.impjournal.org/getFile.php?id=449.</footnote>

<footnote n="192">¹⁹² Painter-Morland (2007a), p. 516. Also: J. Mitchell, D. Shepherd, and M. Sharfman (2011). ‘Erratic strategic decisions. When and why managers are inconsistent in strategic decision making’, *Strategic Management Journal*, Vol. 32, No. 7, pp. 683–704.</footnote>

<footnote n="193">¹⁹³ Van Bussel (2020), pp. 21–54. Also: I. Simonson, and P. Nye (1992). ‘The effect of accountability on susceptibility to decision errors’, *Organizational Behaviour and Human Decision Processes*, Vol. 51, No. 3, pp. 416–446.</footnote>

<footnote n="194">¹⁹⁴ Van Bussel (2020), pp. 25–35. Also: J. Etienne (2010). *The Impact of Regulatory Policy on Individual Behaviour. A Goal Framing Theory Approach*. Centre for Analysis of Risk and Regulation Discussion Paper, no. 59, London School of Economics and Political Science, London, p. 9.</footnote>
mation) technology will enforce transparency and accountability. It
will, but not always, and it is not guaranteed. <fnref n="195" /> More and stricter
information systems could also result in misbehaviour, as has been
shown here before. <fnref n="196" /> Already more than twenty years ago, in 1995,
Helen Nissenbaum expressed concerns about the effects of compu-
ting technology on the possibility to maintain a robust culture of
accountability. <fnref n="197" /> She was not the first scholar that was concerned
with the effects of computers on phenomena like accountability. <fnref n="198" />

<footnote n="195">¹⁹⁵ V. Pina, L. Torres, and S. Royo (2007). ‘Are ICTs improving transparency and accountability in the EU regional and local governments? An empirical study’, *Public Administration*, Vol. 85, No. 2, pp. 449–472; D. Zinnbauer (2012). ‘Governments using ICTs for integrity and accountability. Some thoughts on an emergent research and advocacy agenda’, A. Finlay (ed.), *The Internet and Corruption. Transparency and Accountability Online*. Global Information Society Watch 2012, APC and Hivos, Copenhagen, pp. 12–15; S. Finnegan (2012). ‘Using technology for collaborative transparency. Risks and opportunities’, A. Finlay (ed.), *The Internet and Corruption. Transparency and Accountability Online*. Global Information Society Watch 2012, APC and Hivos, Copenhagen, pp. 24–28.</footnote>

<footnote n="196">¹⁹⁶ See before pp. 37–38.</footnote>

<footnote n="197">¹⁹⁷ H. Nissenbaum (1995). ‘Computing and accountability’, D.G. Johnson, and H. Nissenbaum, *Computers, Ethics, and Social Values*, Pearson Education, New York, chapter 6, pp. 526–537. Repeated in: H. Nissenbaum (1996). ‘Accountability in a computerized society’, *Science and Engineering Ethics*, Vol. 2, No. 1, pp. 25–42.</footnote>

<footnote n="198">¹⁹⁸ J. Ladd (1989). ‘Computers and moral responsibility. A framework for an ethical analysis’, C. Gould (ed.), *The Information Web. Ethical and Social Implications of Computer Networking*, Westview Press, Boulder, pp. 207–228; B. Friedman and P.H. Kahn, Jr. (1992). ‘Human agency and responsible computing. Implications for computer-system design’, *Journal of Systems and Software*, Vol. 17, No. 1, pp. 7–14; D.G. Johnson and J.M. Mulvey (1995). ‘Accountability and computer decision systems’, *Communications of the ACM*, Vol. 38, No. 2, pp. 58–64.</footnote>
Problematic professional ethics lead to excuses for computer failures to avoid responsibility. <fnref n="199" /> Nissenbaum defined four barriers to accountability, of which the last one is the most difficult to solve: ownership without liability, the fact that based on intellectual property rights, software developing companies ‘demand maximal property protection while denying, to the extent possible, accountability.’ <fnref n="200" /> In 2018, it is still emphasized that eroding accountability in technological environments is a problem within third-party relationships, within the cloud infrastructure, and in the deployment of machines, bots, and black boxes. <fnref n="201" /> Kirsten Martin studied the unclear responsibilities for algorithms that make machines, bots and black boxes work. Her conclusion, counter to current arguments,

<footnote n="199">¹⁹⁹ For an overview of such excuses: D. Gotterbarn (2001). ‘Informatics and professional responsibility’, *Science and Engineering Ethics*, Vol. 7, No. 2, pp. 221–230, p. 226.</footnote>

<footnote n="200">²⁰⁰ Nissenbaum (1996), p. 36. The first barriers are: (1) the ‘problem of many hands’ (many people are engaged in developing software, so: who is accountable for what?); (2) ‘bugs’, software errors (they are a ‘fact of life’, so it is ‘unreasonable’ to hold software developers to account), and (3) the ‘computer as scapegoat’ (‘we do not know who is accountable, so it should be the computer’). Shay David offers a new perspective on the fourth barrier (property rights), when arguing that developing software collaboratively, licensing it openly, and distributing it freely could be potential remedies to the erosion of accountability. See: S. David (2004). ‘Opening the sources of accountability’, *First Monday*, Vol. 9, No. 11. Online source, retrieved on November 19, 2021, from: https://firstmonday.org/ojs/index.php/fm/article/view/1185.</footnote>

<footnote n="201">²⁰¹ EY (2018). *As Technology Advances, will Accountability be a Casualty? Report of EY Global Regulatory Network, no. 012562-18Gbl, EYGM, London, pp. 4–7*. Online source, retrieved on November 19, 2021, from: https://assets.ey.com/content/dam/ey-sites/ey-com/en gl/topics/banking-and-capital-markets/ey-global_regulatory_network_as_technology_advances_will_accountability_be_a_casualty.pdf.</footnote>
is that if an algorithm is designed to take responsibility of a decision
itself, precluding individuals to be responsible, the designer of the
algorithm should be held accountable for all (ethical) implications
of its application. 202 An algorithm, after all, is not neutral, it is value
laden. Its ‘operational parameters are specified by developers and
configured by users with desired outcomes in mind that privilege
some values and interests over others.’ 203 Besides this, in the evolv-
ing man-machine relationship, ethical demands, such as security,
fairness, and privacy, are extremely important. The establishment
of man-machine trust starts with the accountability of algorithms.
204 Last, but not least, information security is a forgotten, but major

<footnote n="202">202 Martin (2019), pp. 835–850. Advanced machine-generated decision-making technologies are not transparent in the logic and the making of decisions. This is problematic as, for instance, the General Data Protection Regulation offers in articles 15 (h) and 22 (3) a ‘right to an explanation’ and a ‘human intervention’ provision. An individual, as a subject to fully automated decision-making, may ask for an explanation as to how that decision was reached and to a human review of the decision. This is problematic for artificial intelligence and machine learning technologies, since explainability and transparency are difficult to realize. Developers of algorithms are not transparent on how they work citing property rights and business secrets, but their customers are, in the end, accountable for the algorithm’s consequences. That is, in essence, unethical. Martin’s conclusion to hold the developers accountable may be the only sensible one. See: V. Beaudouin, I. Bloch, D. Bounie, S. Clémençon, F. d’Alché-Buc, J. Eagan, W. Maxwell, P. Mozharovskyi, and J. Parekh (2020). *Flexible and Context-Specific AI Explainability. A Multidisciplinary Approach*, Institut Polytechnique de Paris, HAL. Online source, retrieved on November 19, 2021, from: https://hal.telecom-paris.fr/hal-02506409/document.</footnote>

<footnote n="203">203 Mittelstadt, et al. (2016), p. 1. A map of the ethics of algorithms is pro-
posed, with practical evidence of ethical failures of algorithms.</footnote>

<footnote n="204">204 L. Weilling, and L. Deng (2019). ‘Legal construction of algorithm interpretation. Path of algorithm accountability’, *Naveiñ Reet*. *Nordic Journal of*</footnote>
concern. According to Zhifeng Xiao, Nandhakumar Kathiresshan,
and Yang Xiao, accountability does not exist in the computer sys-
tems that are nowadays in use.²⁰⁵

In conclusion, accountability failures are not easily fixed with
new regulations in multidirectional, multi-actor environments in
which [1] there is not a direct cause and effect relationship visible,
[2] (strategic) decisions can be erratic, [3] individual perceptions of
dynamic circumstances are causing subjective and irrational behav-
iour, [4] complex computing systems are used and configured with
undefined third-party responsibility and accountability relation-
ships, and [5] a growing amount of hard- en software ‘black boxes’
are operated that automatically reach decisions based on unexplain-
able processes and biases. Organizations can be characterized as such

Law and Social Research, Vol. 9, pp. 171–186, pp. 171–172. The problem Martin emphasized is recognized in recent literature, without accepting her relatively radical conclusion. Most papers concentrate on implementing accountability in the design of algorithms and auditing that design: I. Raji, A. Smart, R.N. White, M. Mitchell, T. Gebru, B. Hutchinson, J. Smith-Loud, D. Theron, and P. Barnes (2020). ‘Closing the AI accountability gap. Defining an end-to-end framework for internal algorithmic auditing’, *FAT ’20. Proceedings of the 2020 Conference on Fairness, Accountability, and Transparency*, January 27–30, 2020, Barcelona, Association for Computing Machinery, New York, pp. 33–44; and M. Wierenga (2020). ‘What to account for when accounting for algorithms. A systematic literature review on algorithmic accountability’, *FAT ’20. Proceedings of the 2020 Conference on Fairness, Accountability, and Transparency*, January 27–30, 2020, Barcelona, Association for Computing Machinery, New York, pp. 1–18.

205 Z. Xiao, N. Kathiresshan, and Y. Xiao (2016). ‘A survey of accountability in computer networks and distributed systems’, *Security and Communication Networks*, Vol. 9, No. 4, pp. 290–315, p. 290. A taxonomy of accountability problems (and possible solutions) is offered for metrics, logging, internet and networks, distributed systems, cloud, and smart grids.
complex environments, even if organizational leaders do not really
comprehend how complex their organizations have become. They
also do not seem to realize how important the governance and man-
agement of information is in such complex constellations. 206

ACCOUNTABILITY: THE CONCEPT

********

Janus-faced

Over the last two decades, in writings on law and politics, the
accountability concept is omnipresent. While it does not belong to
the most important political ideals, like democracy, constitutional-
ism, the rule of law, and human rights, it assists each of those ideals
to pursue and reach their respective ends. The concept does not ra-
diate a legal or political vision (as the most important ideals do) but
supplies a power-constraining mechanism that hinges on the role,
place and social weight of the organization(s) or individual(s) that is
(are) held accountable. 207 It can serve various masters and is seen as
a chameleonic concept. 208 The core meaning of the concept, how-

<footnote n="206">206 C.W. Choo (2016). *The Inquiring Organization. How Organizations Ac-
quire Knowledge and Seek Information*, Oxford University Press, Oxford
and New York, especially pp. 65–90, pp. 141–168.</footnote>

<footnote n="207">207 D.H. Rached (2016). ‘The concept(s) of accountability. Form in search of substance’, *Leiden Journal of International Law*, Vol. 29, No. 2, pp. 317–342, p. 318.</footnote>

<footnote n="208">208 Concern about what the concept is about is widespread in literature. Examples: It is an ‘appealing but elusive concept’: Bovens (2007a), p. 467. It also ‘represents an underexplored concept whose meaning remains evasive, whose boundaries are fuzzy, and whose internal structure is confusing’: A. Schedler (1999). ‘Conceptualizing accountability’, A. Schedler, L.</footnote>
ever, is clear: ‘being accountable’, and although many interpreta-
tions are possible based on context, the concept is, in my opinion,
not as ‘elusive’ of ‘chameleon-like’ as is presented in literature. Still,
Jerry Mashaw is correct when stating that there are many regimes
of accountability without transparent organizational translations.
When several of those regimes are relevant for an organization, it
might be difficult or even impossible to meet the requirements for
accountability for all of them. <fnref n="209" /> Accountability, ‘being accounta-
ble’, has become a key concept in discussions of governance. <fnref n="210" />

Accountability is a Janus-faced concept, with three intertwined dualities. According to Danielle Rached, those dualities allow accountability to be (1) descriptive or normative, a ‘purposeful enterprise’ or ‘an inevitable social fact’; (2) political or extra-political, cutting ‘across the conventionalized borders between politics and other spheres of social life’; and (3) legal or extra-legal, ‘more or less enmeshed with law.’ <fnref n="211" /> These dualities allow accountability to be

<footnote>Diamond and M. Plattner (eds.), *The Self-Restraining State. Power and Accountability in New Democracies*, Lynne Rienner Publishers, Colorado, pp. 13–28, p. 13. It reveals also a ‘chameleon quality’ and the concept ‘is subjectively constructed and changes with context’. A. Sinclair (1995). ‘The chameleon of accountability. Forms and discourses’, *Accounting, Organisations and Society*, Vol 20, No. 2/3, pp. 219–237, p. 219.</footnote>

<footnote n="209">²⁰⁹ J.L. Mashaw (2006). ‘Accountability and institutional design. Some thoughts on the grammar of governance’, M. Dowdle (ed.), *Public Accountability. Designs, Dilemmas and Experiences*, Cambridge University Press, Cambridge, pp. 115–156. He states (p. 118): ‘The ubiquity of accountability regimes, and our entanglement in scores if not hundreds of them simultaneously, complicates the task of sorting regimes by family, genus and species.’</footnote>

<footnote n="210">²¹⁰ Castiglione (2007), pp. 1.</footnote>

<footnote n="211">²¹¹ Rached (2016), p. 319. R.B. Stewart (2014). ‘Remedying disregard in global regulatory governance. Accountability, participation, and respon-</footnote>
seen as a solution to a wide range of problems, a solution resulting respectively in transparency and openness, access to (impartial) 'judges' to challenge abuse of authority, pressure that will promote appropriate behaviour, and improvements in the service quality of government or business organizations. All these 'promises', as Dubnick calls these 'solutions', can result in distractions and misunderstandings of the concept. 212 For instance, equating accountability with justice and democracy proves frustrating. 'Being accountable' before a reconciliation commission is not equal to having received justice. 213 Implying accountability in holding elections is not the same as having achieved democracy, or liberty. 214 More significantly, it is uncertain if such accountability solutions achieve their aims. 215 Keeping in mind that organizations are multidirectional

<footnote>siveness', *The American Journal of International Law*, Vol. 108, No. 2, pp. 211-270, pp. 246-247, recognizes two different types of accountability (mechanisms): accountability (mechanisms) based on delegation of authority and accountability based on law. The difference is, in my opinion, more about the fact that accountability based on law is primarily *mandatory prescribed and directed by law*, while accountability based on delegation of authority is primarily based on *agreements* (norms, standards, etc.) between different parties (mostly based on legal requirements). Both types of accountability need rules and regulations to answer questions about *who*, *about what*, *when*, and *to whom* individuals are accountable.</footnote>

<footnote n="212">212 Dubnick (2005), pp. 376-377, p. 380.</footnote>

<footnote n="213">213 Judge Richard J. Goldstone illustrates this inequality in his very insightful 'Foreword' to: M. Minow (1998). *Between Vengeance and Forgiveness. Facing History after Genocide and Mass Violence*, Beacon Press, Boston, pp. ix-xiii.</footnote>

<footnote n="214">214 F. Zakaria (2007). *The Future of Freedom. Illiberal Democracy at Home and Abroad*, W.W. Norton, New York.</footnote>

<footnote n="215">215 As was, in 2002, expressed by Onora O'Neill in one of her BBC Lectures about the 'new accountability', which 'often obstructs the proper aims of professional practice. Police procedures for preparing cases are so demand-</footnote>
and multi-actor with invisible cause and effect relationships, erratic
(strategic) decisions, subjective and irrational behaviour, undefined
third-party responsibility and accountability, and automatic and
unexplainable ‘black boxes’, *that* is not really surprising. Neverthe-
less, laws, rules, and regulations *do* expect individuals and organiza-
tions to be accountable and to find solutions for ‘being accountable’
for decisions, policies, products, actions, and transactions, especially
when that ‘account’ is mandatory prescribed and directed by law.
Before paying attention to the different manifestations of accounta-
bility (Mashaw’s different accountability regimes) that influence
everyday organizational life, an overview of how the concept is de-
fined and explained in scholarly literature, is needed.

Different meanings

Although the core meaning of accountability is clear, it is diffi-
cult to define in specific contexts, stimulating academics to use their
own concepts. As mentioned before, the vagueness of the concept
has been emphasized many times. It has been called ‘conceptually
and empirically slippery,’ 216 and ‘complex and chameleon-like.’ 217

ing that fewer cases can be prepared, and fewer criminals brought to court.
Doctors speak of the inroads that required record-keeping makes into the
time they can spend finding out what is wrong with their patients and lis-
tening to their patients. Even children are not exempt from the new ac-
countability: exams are more frequent and time for learning shrinks. In
many parts of the public sector, complaint procedures are so burdensome
that avoiding complaints, including ill-founded complaints, becomes a cen-
tral institutional goal in its own right.' O. O'Neill (2002). *A Question of
Trust*. The BBC Reith Lectures, Cambridge University Press, Cambridge, pp.
49-50.

<footnote n="216">216 Dubnick, and Justice (2004), p. 1.</footnote>

<footnote n="217">217 R. Mulgan (2000). ‘Accountability. An ever-expanding concept?’, *Public Administration*, Vol. 78, No. 3, pp. 555–573, p. 555.</footnote>
The contextual meaning of the concept is, hence, primarily depend-
ent on the purpose of use,<fnref n="218" /> making it into a contestable concept,
because ‘there is no general consensus about the standards for ac-
countable behaviour’, for ‘being accountable.’ <fnref n="219" />

The way accountability is viewed depends also on the metaphor
used to analyse organizations. Gareth Morgan distinguishes eight
‘organizational’ metaphors (or, in his words, ‘images’): organiza-
tions as machines, as organisms, as brains, as cultures, as political
systems, as psychic prisons, as flux and transformation, and as in-
struments of domination. <fnref n="220" /> Metaphors are used to interpret mean-
ings and to make sense of the world or a phenomenon. They are a
‘way of thinking’ and a ‘way of seeing.’ <fnref n="221" /> They are components in
processes of sensemaking, generating new (individual or shared) un-
derstandings and, based on those understandings, new (individual
or shared) acts. <fnref n="222" /> Although metaphors can help develop new per-
spectives, they are inherently paradoxical. They create powerful in-
sights but also powerful distortions: ways of seeing and understand-
ing also become ways of unseeing and misunderstanding. <fnref n="223" /> Mor-

<footnote n="218">²¹⁸ Hood (2010); Mulgan (2000). Mulgan analyses the extension of scope and meaning of the concept beyond its core sense of ‘being accountable.’</footnote>

<footnote n="219">²¹⁹ Bovens (2007a), p. 449.</footnote>

<footnote n="220">²²⁰ G. Morgan (2006). *Images of Organization*, SAGE Publications, Thousand Oaks, London (updated edition)</footnote>

<footnote n="221">²²¹ Morgan (2006), p. 4. For Morgan’s view, criticism, and acclaim, see: A. Örtenblad, L.L. Putnam, and K. Trehan (2016). ‘Beyond Morgan’s eight metaphors. Adding to and developing organization theory’, *Human Relations*, Vol. 69, No. 4, pp. 875–889.</footnote>

<footnote n="222">²²² C.D. Jacobs, and L.T. Heracleous (2006). ‘Constructing shared understanding. The role of embodied metaphors in organization development’, *The Journal of Behavioral Science*, Vol. 42, No. 2, pp. 207–226, pp. 208–209.
See also: Van Bussel (2020), p. 82, footnote 222.</footnote>

<footnote n="223">²²³ Morgan (2006), pp. 4–5.</footnote>
gan’s idea is that one should make use of several metaphors, as in-
sights from one metaphor can help to overcome the limitations of
another. His basic message is that organizations are *what you want
to see in them*.<fnref n="224" /> In governance and accountability terms it is *what
you think you see them do*. Mashaw already emphasized that the con-
cept can mean different things to different people, different roles,
and different organizations. <fnref n="225" /> The scholarly and managerial inter-
pretations, views, and frameworks of ‘being accountable’ are all
based on metaphors used to study and analyse organizations.

Accountability as a virtue or as a mechanism

Mark Bovens differentiates between accountability as a virtue and as a mechanism. <fnref n="226" /> In American discourse, ‘being accountable’ is a *virtue*, a positive feature of organizations or individuals, focusing on the assessment of individual or organizational behaviour. Accountability is used as a set of behavioural standards. Accountability as a virtue is an evaluative concept to qualify a state of affairs. It refers to behavioural norms which are hard to define, because there is no consensus about standards for accountable behaviour. Behavioural norms differ, depending on role, time, context, place, the organizational metaphor used, political system, and perspective. <fnref n="227" /> Accountability as a virtue derives from integrity-based ethics management, as described before. Its definition is difficult, because its

<footnote n="224">224 Morgan (2006), p. 342.</footnote>

<footnote n="225">²²⁵ Mashaw (2006), p. 118.</footnote>

<footnote n="226">²²⁶ M. Bovens (2010). ‘Two concepts of accountability. Accountability as a virtue and as a mechanism’, *West European Politics*, Vol 33, No. 5, 946–967, esp. 948–954.</footnote>

<footnote n="227">²²⁷ Bovens (2010), p. 949. Also M. Bovens (2007b). ‘New forms of accountability and EU-governance’, *Comparative European Politics*, Vol. 5, No. 1, pp. 104–120, p. 106.</footnote>
character is essentially contested and broad in interpretation. It is
very difficult to establish whether an organization lives up to expec-
tations, because several defining elements like transparency, liabil-
ity, controllability, responsibility, and responsiveness are in itself
concepts that are difficult to define in context. They need opera-
tionalization and it is uncertain how they can be measured.<fnref n="228" /> Nev-
ertheless, there are frameworks that emphasize this view of account-
ability. One framework is based on (*social psychology* theory view-
ing accountability as *behavioural* expectations, perceptions, and ex-
planations. <fnref n="229" /> A second framework is based on *sociology* and pre-
sents a *relational* accountability framework. Predominant are social
relationships, the dynamics of power, structures, processes, and so-
sial complexities. This framework seeks to understand *how* people
as social actors perform in their roles, and *how* the quality of rela-
tionships influences the character of accountability. The steward-
ship theory, for instance, emphasizes that in organizations *relation-
ship-centred collaboration* fosters pro-organizational and trustwor-
thy behaviour in managers.<fnref n="230" />

<footnote n="228">²²⁸ Bovens (2010), p. 950. See also: J. Koppell (2005). ‘Pathologies of accountability. ICANN and the challenge of ‘multiple accountabilities disorder’’, *Public Administration Review*, Vol. 65, No. 1, 94–107, p. 95–99.</footnote>

<footnote n="229">²²⁹ Among others: J.S. Lerner, and P.E. Tetlock (1999). ‘Accounting for the effects of accountability’, *Psychological Bulletin*, Vol. 125, No. 2, pp. 255–275; A.T. Hall, M.G. Bowen, G.R. Ferris, M. Todd Royle, and D.F. Fitzgibbons (2007). ‘The accountability lens. A new way to view management issues’, *Business Horizons*, Vol. 50, No. 5, pp. 405–413; and A.T. Hall, D.D. Frink, and M.R. Buckley (2017). ‘An accountability account. A review and synthesis of the theoretical and empirical research on felt accountability’, *Journal of Organizational Behavior*, Vol. 38, No. 2, pp. 204–224.</footnote>

<footnote n="230">²³⁰ Relational accountability: J. Moncrieffe (2011). *Relational Accountability. Complexities of Structural Injustice*, Zed Books, London. Also: Heidelberg (2017), and O’Kelly, and Dubnick (2019). Stewardship theory: M.</footnote>
Accountability as a *mechanism* is a more narrow, descriptive interpretation of the concept. It is closely related to compliance-based ethics management. The concept is interpreted as a social mechanism, an institutional arrangement in which an ‘accountee’ (‘actor’, ‘delegate’ or ‘agent’) can be held to account by an ‘accountor’ (‘debator’, ‘principal’, or ‘forum.’)<fnref n="231" /> It emphasizes the way this institutional arrangement operates when holding individuals and/or organizations to account. This view is not about the question whether an accountee behaves accountable (or not), but whether this accountee can be held accountable *post factum* by an accountor.<fnref n="232" /> It is a relationship of power: the capacity to *demand* to justify behaviour in policies, decisions, products, actions, and transactions (*right to question*), and the capacity to *impose a sanction* if that behaviour is

<footnote>Hernandez (2012). 'Toward an understanding of the psychology of stewardship', *The Academy of Management Review*, Vol. 37, No. 2, pp. 172-193.</footnote>

<footnote n="231">²³¹ Dubnick (2005), pp. 381-382, states that this approach is based on the social mechanism approach, as defined by P. Hedström and R. Swedberg (1998). 'Social mechanisms. An introductory essay', P. Hedström and R. Swedberg (eds.), *Social Mechanisms. An Analytical Approach to Social Theory*, Cambridge University Press, Cambridge, pp. 1-31, p. 7: 'a mechanism can be seen as a systematic set of statements that provide a plausible account of how I and O are linked to one another.' According to T. Schelling (1998). 'Social mechanisms and social dynamics', P. Hedström and R. Swedberg (eds.), *Social Mechanisms. An Analytical Approach to Social Theory*, Cambridge University Press, Cambridge, pp. 32-44, p. 33, this could be a relation between an accountee and an accountor (p. 33): 'interactions between individuals and other individuals, or between individuals and some social aggregate.'</footnote>

<footnote n="232">²³² Bovens (2007a), p. 450-452. See also: S. Gailmard (2014). 'Accountability and principal-agent theory', M. Bovens, R.E. Goodin, and T. Schillemans (eds.), *The Oxford Handbook of Public Accountability*, Oxford University Press, Oxford, chapter 6, pp. 90-105.</footnote>
(not) in agreement with what the accountor expects (*right to approve or punish*.) It is the *answerability* for actions and behaviour, defined in social relations of responsibility, obligation, and duty.<fnref n="233" /> As such, acts of ‘account giving’ and ‘account receiving’ can be viewed as ‘speech acts’, associated with acts of rationalization and justification. <fnref n="234" /> These expectations of rationalization and justification are assumed to bring about appropriate behaviour. <fnref n="235" /> It is clear that accountors that are in a position to take (authoritative) decisions are objects within accountability relations, just like the accountees to which they have delegated (parts of) their authority. <fnref n="236" /> Accountees use authority to act for the accountor. Rules constitute the bounds within which delegated actions take place and the accountor has the rights to question and to punish or approve. <fnref n="237" /> Scholars have defined theories and frameworks here, too. The first one is a *mechanistic* or *bureaucratic* framework, in which accountability is studied using agency and behavioural agency theories to deal with compli-

<footnote n="233">²³³ Bovens (2007a); Mulgan (2000); Gailmard (2014).</footnote>

<footnote n="234">²³⁴ P. Henttonen (2017). ‘Looking at archival concepts and practice in the light of speech act theory’, A.J. Gilliland, S. McKemmish, and A.J. Lau (eds.), *Research in the Archival Multiverse*, Monash University Publishing, Clayton, pp. 537–557; and G. Yeo (2017). ‘Information, records, and the philosophy of speech acts’, F. Smit, A. Glaudemans, and R. Jonker (eds.), *Archives in Liquid Times*, Stichting Archiefpublicaties, ‘s Gravenhage, pp. 92–119.</footnote>

<footnote n="235">²³⁵ M.J. Dubnick, and H.G. Frederickson (2011). ‘Introduction. The promises of accountability research’, M.J. Dubnick, and H.G. Frederickson (eds.), *Accountable Governance. Problems and Promises*, M.E. Sharpe, Armonk, New York, pp. xiii–xxxii, p. xvi.</footnote>

<footnote n="236">²³⁶ Lindberg (2013), p. 203.</footnote>

<footnote n="237">²³⁷ K. Strøm (2000). ‘Delegation and accountability in parliamentary democracies’, *European Journal of Political Research*, Vol. 37, No. 3, pp. 261–290.</footnote>
ance issues in the ‘principal-agent relationship,’ the ‘accountor-ac-
countee relationship.’<sup>238</sup> Closely related to this framework is the
theory that treats accountability as an institutional *function of ‘gov-
erning’*. Starting point of this approach are ‘the fluidity, ambiguities,
inconsistencies, and tensions’ of ‘governing’ and ‘the evolving na-
ture of who is accountable to whom for what under different con-
tingencies and with what implications.’<sup>239</sup>

Just like integrity-based and compliance-based ethics manage-
ment, accountability as a virtue and as a mechanism are closely re-
lated. The broad one sees accountability as a personal or organiza-
tional virtue, and the narrow one defines accountability as a social
mechanism. Accountability as a virtue provides *legitimacy*, account-
ability as a mechanism *accountable governance* (the activity of gov-
erning.)<sup>240</sup> Although both views need to be distinguished, as they
address different issues and imply different standards and analytical
dimensions, only their combined use could make accountability
possible in multi-directional en multi-actor environments in which

<footnote n="238">238 On agency theory: Gailmard (2014); B. Panda, and N.M. Leepsa (2017). ‘Agency theory. Review of theory and evidence on problems and perspectives’, *Indian Journal of Corporate Governance*, Vol. 10, No. 1, pp. 74–95. For behavioural agency: A. Pepper, and J. Gore (2012). ‘Behavioral Agency Theory. New foundations for theorizing about executive compensation’, *Journal of Management*, Vol. 41, No. 4, pp. 1045–1068.</footnote>

<footnote n="239">²³⁹ J.P. Olsen (2017). ‘The organizational basis of accountability. Settled and unsettled policies’, J.P. Olsen, *Democratic Accountability, Political Order, and Change. Exploring Accountability Processes in an Era of European Transformation*, Oxford University Press, Oxford, chapter 2, pp. 27–52, p. 29. Interesting for this approach is also: J.P. Olsen (2017). ‘Ambiguity and the politics of accountability’, J.P. Olsen, *Democratic Accountability, Political Order, and Change. Exploring Accountability Processes in an Era of European Transformation*, Oxford University Press, Oxford, chapter 4, pp. 74–96.</footnote>

<footnote n="240">²⁴⁰ Bovens (2010), p. 954.</footnote>
(possibly) countless automatic ‘black boxes’ function that influence
decision-making. Just as with integrity-based and compliance-
based ethics management, in organizational practice both views
need to be balanced.

Accountability’s core structure

Accountability (in both interpretations) is about ‘being account-
able.’ It *only* exists where an accountee (a manager, banker, trader,
or civil servant) has an obligation to account for actions or inactions
in policies, decisions, products, actions, and transactions (acknowl-
edging answerability and responsibility), and where the parties in-
volved (shareholders, citizens, professional committees, review bod-
ies, courts, or virtual entities (such as ‘the general public’)) are enti-
tled to demand such an account.<fnref n="241" /> Defined as such, accountability
puts a limit, to varying degrees, on the autonomy of accountees, and
defines de boundaries of acceptable behaviour. Such limitations and
boundaries differ across space and time, just like the extent they can
curb accountees. In short, the core structure of accountability is
about a social relationship between an accountee and a ‘significant

<footnote n="241">241 Rached (2016), p. 323; Mulgan (2000), p. 555. Mulgan identifies a ‘core sense’ of accountability with ‘three key features’. It is, first, external to a person or organization as the account is always given to an outside authority. It, second, involves social interaction and exchange, with an accountor expecting or demanding (and receiving) account giving, while the accountee responds and, if necessary, accepts sanctions; and third, it implies rights of authority, where the accountor asserts authority over an accountee. N.C.Manson and O.O’Neill (2007). *Rethinking Informed Consent in Bioethics*, Cambridge, Cambridge University Press, chapter 7, pp. 154–182, p. 167: ‘Systems of accountability are highly varied, but *they have a common formal structure*. They are used to define, assign and help enforce second-order obligations to account for the performance (or non-performance) of primary or first-order tasks or obligations’ (my italicization — GJvB.)</footnote>
other', in which this 'other', the accountor, has the ability to de-
mand an account.<fnref n="242" /> It engenders 'an ongoing process of account-
giving and account-taking.' <fnref n="243" /> Accountability, unlike 'responsibil-
ity', indicates that an accountee (an individual or an organization)
has the duty to provide an 'explanation.' <fnref n="244" /> Regardless of the exist-
ing accountability relationship, at least five questions should be an-
swered: Who is accountable to whom? What is the subject of the
account? What are the procedures by which accountability is to be
assured? By what standards is accountable behaviour to be judged?
What are the consequences for (non-)acceptable behaviour? The
basic features of accountability relations, thus, are who, to whom,
about what, through what procedures, by what standards, and which
consequences for (non-)compliance. <fnref n="245" /> Answering these fundamental
questions will be needed to allow for analysis of the 'ordinary cycle
of accountability' which revolves around 'exchanges of informa-
tion, justification and judgment.' <fnref n="246" />

Edward Weisband and Alnoor Ebrahim add ‘four core compo-
nents of accountability’ to these questions, which impress the ne-
cessity for information governance in organizations. Accountabil-

<footnote n="242">²⁴² Rached (2016), p. 323, uses ‘decision-maker’ and ‘power-holder’. ‘Significant others’: Bovens (2010), p. 951.</footnote>

<footnote n="243">²⁴³ Dubnick (2002), p. 5.</footnote>

<footnote n="244">²⁴⁴ M.T. Kamminga (1992). *Inter-State Accountability for Violations of Human Rights*, University of Pennsylvania Press, Philadelphia, p. 5. Responsibility indicates that an accountee has the duty to provide ‘reparation.’</footnote>

<footnote n="245">²⁴⁵ These questions are defined in similar formulations by: Rached (2016), pp. 323–324; Mashaw (2006), pp. 117–118; R. Mulgan (2003). *Holding power to Account. Accountability in Modern Democracies*, Palgrave MacMillan, Basingstoke, New York, pp. 22–30; and Stewart (2014), pp. 245–247.</footnote>

<footnote n="246">²⁴⁶ P.C. Schmitter (2004). ‘The quality of democracy. The ambiguous virtues of accountability’, *Journal of Democracy*, Vol. 15, No. 4, pp. 47–60, p. 49.</footnote>
ity needs the presence of all four. These (overlapping) components
are: [1] Transparency, access to information about policies, deci-
sions, products, actions, and transactions for all parties in the ac-
countability relationship; [2] Answerability (or justification), pro-
viding logical and clear reasoning, based on evidence, for the recon-
struction of policies, decisions, products, actions, and transactions;
[3] Compliance, monitoring, evaluation, and control of procedures
and outcomes, combined with transparency in reporting; and [4]
Enforcement, imposing (and accepting) sanctions and rewards for
(non-) compliance, justification, or transparency.<fnref n="247" /> Just like the
basic features of accountability relationships, these four compo-
nents rely on evidence: the reason why the accessibility of infor-
mation on policies, decisions, products, actions, and transactions is
crucial for organizational governance and its objectives: perfor-
mance and accountability. Information governance should, for that
reason, be an important focus for organizational leaders to realize
organizational objectives. The defining features and components of
accountability seem to capture the core of the concept. The account-
ability concept does not specify that it has to be formally codified
or that the only parties involved are formal institutions. But its need
for information emphasizes the role on enterprise information man-
agement.

Accountable governance is a requirement for organizations. The core of the accountability concept, the defining features and the components, are clear. But the concept presents itself in multiple manifestations in and to organizations. What is this accountability puzzle organizations need to solve?

<footnote n="247">247 E. Weisband, and A. Ebrahim (2007). ‘Introduction. Forging global ac-
countabilities’, E. Weisband, and A. Ebrahim (eds.), *Global Accountabili-
ties. Participation, Pluralism, and Public Ethics*, Cambridge University
Press, Cambridge, New York, pp. 1–23, pp. 5–6.</footnote>
4

ORGANIZATIONAL ACCOUNTABILITY
AND ITS MULTIPLE MANIFESTATIONS

*
SOURCE, POWER, AND SPACE

********

Organizational accountability is characterized by three dimen-
sions: its source, its degree of control, and its spatial direction, alt-
hough hybridity is gaining ground. <fnref n="248" /> These dimensions (even in
hybrid forms) characterize every manifestation of organizational ac-
countability. The first dimension, source, is a basic but essential one:
the accountor in the accountability relationship. However, it is not
as straightforward as it seems. The source can be [1] external or in-
ternal to the one being held accountable, and it can be [2] formal or
informal. An external source for accountability means there is an
accountor outside of an organization, an internal source that there
is one in the organization itself. Formal accountability is about the
formal, defined processes, procedures, systems and methods, infor-
mal accountability about various methods that are *not* part of the
formal mechanisms. <fnref n="249" /> In an organization, informal accountability
includes its norms and values, its culture and climates, and its inter-
personal relationships. <fnref n="250" /> Although the existence of informal ac-
countability is acknowledged, what its impact is, is not well known.

<footnote n="248">²⁴⁸ Lindberg (2013), p. 212.</footnote>

<footnote n="249">²⁴⁹ H. Pearson, and M. Sutherland (2017). ‘The complexity of the antecedents influencing accountability in organisations’, *European Business Review*, Vol. 29, No. 4, pp. 419–439, pp. 422–424; M.S. Haque (2000). ‘Significance of accountability under the new approach to public governance’, *International Review of Administrative Sciences*, Vol. 66, No. 4, pp. 599–617.</footnote>

<footnote n="250">²⁵⁰ Pearson, and Sutherland (2017), p. 422. Also: B.S. Romzek, K. LeRoux, and J.M. Blackmar (2012). ‘A preliminary theory of informal accountability among network organizational actors’, *Public Administration Review*, Vol. 72, No. 3, pp. 442–453.</footnote>
The effects, for instance, of peer accountability within collaborations of employees or organizations in matrix or network constellations are not well known. 251 However, the consideration of ‘ reputational concerns’ in interpersonal relationships may have effects on accountability that are far beyond the effect of formal accountability processes. Madalina Busuioc and Martin Lodge argue convincingly that personal (and organizational) reputation is extremely important in interpersonal relationships, (inter-)organizational actions and transactions, and accountability interactions between accountors and accountees. Reputation determines the prioritizing of accountability interactions, accountability manifestations, and the subjects to emphasize in accountability processes. It is a filtering mechanism of external demands. 252 Accountors and accountees, be they external or internal, are concerned about how their reputation is viewed by wider (external) networks of ‘audiences’ that value the role of both parties in the accountability process. 253 Organizations and individuals always strive for support and acceptance from their environment, driven by ‘concerns with falling in the esteem of others.’ 254 On the other hand, reputation has an illusory character and

<footnote n="251">251 T. Willems, and W. van Dooren (2011). ‘Lost in diffusion? How collaborative arrangements lead to an accountability paradox’, *International Review of Administrative Sciences*, Vol. 77, No. 3, pp. 505–530.</footnote>

<footnote n="252">252 M. Busuioc, and M. Lodge (2017). ‘Reputation and accountability relationships. Managing accountability expectations through reputation’, *Public Administration Review*, Vol. 77, No. 1, pp. 91–100, p. 92. Also: Romzek, LeRoux, and Blackmar (2012), pp. 447–448, p. 451.</footnote>

<footnote n="253">253 D. Carpenter (2010). *Reputation and Power. Organizational Image and Pharmaceutical Regulation at the FDA*, Princeton University Press, Princeton (NJ), especially Chapter 1, pp. 33–70. An audience: ‘any individual or collective that observes a regulatory organization and can judge it.’ (p. 33)</footnote>

<footnote n="254">254 Romzek, LeRoux, and Blackmar (2012), p. 451. For the citation: P. Tetlock (2002). ‘Social functionalist frameworks for judgment and choice. In-</footnote>
is a matter of perception and presentation. It is (very) subjective and,
essentially, grounded in how organizations and individual employ-
ees present themselves and the perceptions that such a presentation
initiates in the conscious or unconscious minds of accountors and
accountees. Expectations of formal accountability mechanisms are
unmistakable influenced by informal concerns. The expectations of
the parties within the accountability process of each other and the
process they are part of, are (unconsciously) defined by such repu-
tational perceptions and the way each of them presents themselves
as a result of these perceptions. Knowing the ‘other side’ in the ac-
countability interaction helps with presenting an image that con-
firms an existing reputation and meets the expectations and percep-
tions of this ‘other side’. However, when expectations and percep-
tions do not match and are not confirmed with the image shown,
the result of an accountability interaction may be unexpected.²⁵⁵

tuitive politicians, theologians, and prosecutors', *Psychological Review*, Vol. 109, No. 3, pp. 451-471, p. 455.

255 Carpenter (2010), pp. 33–70. This idea is closely related to ‘felt accountability’ but is not the same. ‘Felt accountability’ can be defined as: ‘The (1) implicit or explicit expectation that one’s decisions or actions will be subject to evaluation by (2) some salient audience(s) with the belief that there exists the potential for one to receive either rewards or sanctions based on this expected evaluation.’ This concept applies *only* to the expectations of accountees and is defined as the opposite of the expectations of the ac-countor for accountability. Reputational concerns apply to *both* parties in the accountability relationship and influence perceptions and expectations of accountability processes by both of them. For the definition of ‘felt ac-countability’: W.A. Hochwarter, G.R. Ferris, M.B. Gavin, P.L. Perrewé, A.T. Hall, and D.D. Frink (2007). ‘Political skill as neutralizer of felt ac-countability. Job tension effects on job performance ratings. A longitudi-nal investigation’, *Organizational Behavior and Human Decision Processes*, Vol. 102, No. 2, pp. 226–239, p. 227. About ‘felt’ accountability as being
With multiple manifestations of accountability and multiple accountors, it is possible that many ‘reputational images’ have to be managed. Informal accountability is implicit, not transparent,<fnref n="256" /> and very difficult to grasp within a multidirectional and multi-actor environment, confronted with multiple manifestations of organizational accountability, many different accountors, and (potentially) many perceptions of ‘reputational images.’ Especially in informal accountability, integrity-based ethics management is extremely important.

The second dimension of organizational accountability is *power*, the degree of control that an accountor exercises over an accountee. There are essential differences between fiscal accountability and its detailed control-based mechanisms, and social accountability where control is diffuse and contextual. Power forces organizations and employees to (or not to) behave in a particular way, and it empowers and controls them. In organization science, power is a continuous subject of study. The nature of power is relational, it rests in relational dependencies. Establishment and maintenance of such dependencies are essential for organizational power. Power resides *between* individual employees, leaders, and structures, and is coloured by perceptions grown within relational climates about organizational culture, rules, routines, and external forces.<fnref n="257" /> It shows in

<footnote>opposite to the expectations of accountors: Hall, Frink, and Buckley (2017), p. 207.</footnote>

<footnote n="256">²⁵⁶ Romzek, LeRoux, and Blackmar (2012), p. 443.</footnote>

<footnote n="257">²⁵⁷ P. Fleming, and A. Spicer (2014). ‘Power in management and organization Science’, *Academy of Management Annals*, Vol. 8, No. 1, pp. 237–298, for an extensive overview of literature about power in organizations. See also for important discussions about power in and over organizations: T. Diefenbach, R.T. By, and P. Klarner (2009). ‘A multi-dimensional analysis of managers’ power. Functional, socio-political, interpretive-discursive,</footnote>