As stated in Michael McMillan's report Codes of Ethics: If You Adopt One, Will They Behave?, there is no guarantee that colleagues will behave ethically , that's enough because there is a code of ethics. Andrews will need to ensure that an ethical culture is created and promoted by senior leaders and the board of directors. This means that they must demonstrate their commitment to BBB Bank's ethical values ​​in their daily behavior and actions. Senior management must ensure that employees feel safe to discuss and question ethical and unethical behavior. A code of ethics cannot be just a piece of paper; it needs to be lived and applied every day. Managers should monitor and encourage good behavior in their teams and correct any behavior that does not comply with the