This paper examines how middle managers experienced the implementation and development of an ethics and compliance program (ECP) in a multinational company after a major corruption scandal. Based on semi-structured interviews and archival data, it shows how middle managers responded to the program’s transformation in a context of regulatory reform and intense stakeholder pressure in Brazil. In 2015, the program was characterized by a coercive environment featuring strict rules and procedures, internal investigations, and an unprecedented sanctioning system. It was consolidated through major changes in key organizational processes, especially centralization of procurement processes and segregation of duties. In 2019, middle managers actively participated in a new phase in the program’s development, characterized by an approach that advocated the moral development of employees. Middle managers developed specific practices in response to each of these three phases. This paper proposes a process model of middle managers’ temporal perspective of ECPs following a corruption scandal. The paper contributes to a better understanding of ethics and compliance programs as dynamic processes and to the practices developed by middle management in their development.
