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Economic Crime Survey 2016, for instance, says 94 per cent of the Indian respondents stated that their organisations had a clear code of conduct, yet only 15 per cent indicated that their leaders walk the talk. About 24 per cent mentioned communication and training on ethical behaviour was unclear. Frauds are committed by executives at different levels within a company, but typically by those at junior to middle management level, according to these studies. These include misappropriation of assets, cybercrimes, and procurement frauds, besides bribery and corruption. Sometimes, the top management is involved, as evinced by the growing list of 'wilful defaulters'. The lack of a strong whistleblower law, as well as the absence of an internal culture of encouraging disclosure, has made matters worse. Many instances of fraud, bribery and corruption do not get reported for the fear of retaliation the PwC study attributes that to 19 per cent of the respondents. In other instances, it is the loyalty factor — the EY study found 30 per cent of respondents in India cited loyalty to the company and 28 per cent said loyalty to their colleagues as reason for not reporting. Having an institutional framework to deal with such issues is necessary, but it is equally important to empower it. There are limitations to what a compliance officer can achieve if information of offences does not flow to him or if the management or deviant employee's supervisor is not supportive of his efforts or action recommended. Ethical behaviour can become pervasive within an organisation only if it has a zero tolerance attitude towards bribery, corruption and other economic offences, irrespective of how many laws the government puts in place. That will happen when the top management is seen to be ethical in its dealings and regularly reports deviations and action taken to all the stakeholders. While India Inc is vocal on India's abysmal ease of doing business rankings, it needs to realise that creating an ethical and transparent business culture is as much part of the process to improve it as reducing red tape. Economic Crime Survey 2016, for instance, says 94 per cent of the Indian respondents stated that their organisations had a clear code of conduct, yet only 15 per cent indicated that their leaders walk the talk. About 24 per cent mentioned communication and training on ethical behaviour was unclear. Frauds are committed by executives at different levels within a company, but typically by those at junior to middle management level, according to these studies. These include misappropriation of assets, cybercrimes, and procurement frauds, besides bribery and corruption. Sometimes, the top management is involved, as evinced by the growing list of 'wilful defaulters'. The lack