Interest in understanding ethical culture in organizations has grown over the last few decades. However, ethical culture appears to suffer from a lack of conceptual clarity, leading to downstream problems that threaten the internal and external validity of findings and stunt the ability to build and test theory. To identify conceptual issues in the existing literature, I qualitatively analyzed 121 definitions (76,722 words) to detect themes in how ethical culture is described. These themes revealed ten critical limitations in existing conceptualizations that needed to be addressed. Overall, these limitations indicate that the existing conceptual domain is messy and disorganized and exhibits severe problems regarding levels of analysis. I propose a refined definition that overcomes these limitations by integrating the dynamic model of culture with the concept of ethical affordances from sociocultural anthropology. Taking into account the concept’s multi-level nature, the conceptualization presented encompasses the different levels at which ethical culture is theorized to reside. Finally, I describe how levels are connected through bottom-up and top-down emergent processes.