Following Russia's accession to the WTO in August 2012, Russian economic actors are increasingly committing to internationally accepted corporate governance practices that were not previously common in Russia. This includes the code of conduct, which originates from the American cultural context and has been transferred to the Russian cultural context. Did Russian companies adapt the practice of the code of conduct to their own cultural and institutional context after the transfer, or did they merely copy the American practice? This question is thoroughly examined and answered using empirical and cultural theoretical techniques.