An organizational integrity system consists of the range of institutions, policies, actors, and practices that are meant to promote the integrity of an organization. These include compliance-based mechanisms, values-based mechanisms, and the informal day-to-day practices that contribute to its ethical climate. Crucially, the way in which these various elements of the system interact can have the effect of either mitigating or exacerbating an organization’s vulnerability to integrity violations. This research draws on insights from the field of behavioral ethics to highlight the manner in which a systems approach can aid in assessing and managing the factors that contribute to organizational integrity risks. Along these lines, the integrity system of the U.S. Department of Veterans Affairs (VA) is analyzed, with particular emphasis on a case study of the events surrounding the so-called 2014 waitlist scandal. On one hand, the VA has an elaborate integrity system consisting of conceptually well-designed compliance and values-based mechanisms, especially with respect to its award-winning IntegratedEthics program. On the other hand, certain policies and practices within the VA, as well as a number of external pressures outside its control, had the effect of undermining these formal elements of the system. Consequently, the case of the 2014 VA waitlist scandal appears to have been a perfect storm of integrity risk factors that illustrates the importance of taking a systems approach to managing organizational integrity risks.
