Corporate governance design and the “moral subjectification” of human resources: The role of compliance programs

Previous studies have discussed mutual relationships between corporate governance design and the management of human resources. The same studies call for further research aiming at empirically investigate such relationships. The paper empirically addresses this call exploring how the compliance program, as a corporate mechanism, impacts on the human resources “moral subjectification”. The paper draws on the Michel Foucault’s interpretation of ethics to investigate the compliance program implementation process within a business setting. The findings of the case study, developed through in-depth interviews and documental analysis, show that the compliance program can impact differently on employees depending on how both compliance program elements (i.e. code of conduct, disciplinary system, training sections) and self-governing practices are combined together. In particular, the way in which the compliance program is designed along its elements feeds the process of “moral subjectification”. Such process drives human resources to autonomously follow compliance principles and develop themselves as “moral subjects”. Furthermore, the role played by the compliance program in this process appears to be influenced by the corporate governance design surrounding the compliance program implementation. The results have practical implications as they show that the management of compliance programs should not rely only on compliance program elements, but also favour the enablement of employees as self-governing ethical subjects. The research contributes to the growing debate on the relationships between human resources and corporate governance design.