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This paper contributes to the literature of accountability and ethics by providing historical perspective by way of archival discovery of original, primary documentation as to corporate practices and behaviors of an early major U.S. corporation during the period 1849–1862. The authors provide the results of examination and analysis of surviving corporate records.

The challenges to appropriate behavior and the application of stewardship principles with regard to the custody of property and the sanctions imposed for transgressions are all identified from primary corporate documents and hand-written minutes books of the board of directors of the Mobile & Ohio Railroad during the period. The de facto development of a corporate code of conduct enumerated by the board provides an early example of explicit corporate governance guidance. This unique discovery informs contemporary understanding of ethical issues identified in the accountability literature by adding the perspective of management experiences from over 150 years ago.