How does a large multinational keep thousands of employees, operating in hundreds of countries, honest in a high-pressure business environment? As the chief legal officer at General Electric for nearly 20 years, Ben Heineman was part of the senior management group that sought to do just that--to make sure its executives and employees are moved to do the right thing as strongly as they are motivated to make their numbers. Heineman describes a set of systems that combine the communication of clear expectations with oversight, deterrence, and incentives. Nowhere are the expectations higher--and the sanctions more powerful--than for top executives. Heineman recounts example after example of senior leaders terminated for ethical lapses even when the business consequences of doing so were painful--and even when they had no direct knowledge of the violations occurring on their watch. To make expectations clear throughout the company, GE has systematically sought to set uniform standards that stay well ahead of current legal developments and stakeholders' changing attitudes about corporate accountability. Responsibility for implementing those standards, which are embedded in GE's operating practices, rests with the business leaders in the field. Oversight is both methodical and multifaceted. A host of auditing and assessment systems enables GE to compare the performance of its various business units against one another and against industry benchmarks. Perhaps the most powerful is the company's ombudsman system, which doesn't just allow but requires employees to lodge concerns. Failures to report into the system or up the line, or retaliation in any form, are firing offenses. The current intense focus on board-level governance has missed the point, Heineman argues. It is time to shift the debate from board oversight of the CEO to how top company leaders can most effectively infuse integrity at all levels of the corporation.