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The article deals with the results of a comparative investigation of the corporate codes of ethics in the Western German and Slovak firms. The objective of this study is to highlight the differences between corporate codes of ethics of Western Germany and Slovakia and to analyse, whether they can be traced back to the specific situation of transformation in Slovakia compared to the stable context of the firms in Western Germany. We concentrated our analysis on two areas, the internal and external stakeholders addressed by the codes and the issues highlighted by the codes. With stakeholders we found that Slovak firms address more stakeholders groups in their codes. With the issues highlighted we found that Slovak firms raise more issues in their codes of ethics. We were able to interpret the differences as specific to the transformational situation of the Slovak companies.