A values-based ethics culture . a. excludes Upper Management Board, but relies solely on the Board of Directors to add to general value statements by formulating specific value statements for its strategic business units (SBU) b. is based solely on transparency to help employees identify and deal with ethical issues c. excludes the Board of Directors, but relies solely on Upper Management to add to general value statements by formulating specific value statements for its strategic business units (SBU) d. is based solely on the Office of Best Practices to help employees identify and deal with ethical issues e. relies upon an explicit mission statement that defines the core values of the firm