Legitimating the legitimate: A grounded theory study of legitimacy work among Ethics and Compliance Officers

• Qualitative methods surfaced four internal legitimacy challenges facing Ethics and Compliance Officers.
• Two facilitating conditions reduce the necessity for ECOs to legitimate their work.
• “Legitimacy work tactics” aim to address internal legitimacy challenges.
• Tactics rely on advancing cognitive, instrumental, moral legitimacy, and relational legitimacy.

Organizations have responded to ethical scandals in part by creating the Ethics and Compliance Officer (ECO) role to help insure employee ethical and legal behavior. Because ECO work is so fundamental to behavioral ethics in organizations and we know very little about it, we conducted a grounded theory study to learn more. We learned that, although most ECOs were hired to help their organizations respond to external legitimacy challenges, ECOs face major legitimacy challenges inside their organizations. Facilitating conditions may reduce these challenges and help ECOs reach internal legitimacy. But, we also found that ECOs engage in what we term legitimacy work that relies on a number of tactics to help them gain legitimacy in the eyes of their constituents. We tie our findings to the broader legitimacy literature and draw implications for the behavioral ethics literature.