Implementing ethical management in organizations is becoming increasingly fundamental for the transparency of its management and solidifying its corporate governance. Therefore, the objective of this study is to analyze the instruments used by the Brazilian and Portuguese organizations to implement ethical management and highlight its drawbacks from a cultural perspective. Thus, an analytical, descriptive, exploratory and qualitative study was undertaken using secondary data and selecting a list of large Brazilian and Portuguese corporations according to the criterion of accessibility and availability. The companies’ Codes of Ethics and Conduct were analyzed for their content according to the following constructs: relationships with associates and stakeholders; communication; internalization; indicators and recognition, and these constructs were subdivided into categories, making a comparison between the documents collected from different companies in both countries. The conclusion is that the codes generally have similar structure and content both at an organizational and national level with regard to relationships, being, however, different with regard to the other four constructs; and that Brazilian and Portuguese cultural traits such as centralization; paternalism; family; formalism and impunity, to name a few, hinder the implementation of ethical management in organizations in both countries.