ABSTRACT: Corporate Social Responsibility (CSR) promotes and incorporates ethical activity in business practices and has been embraced by 90% of Fortune 500 firms in the world. However, the incorporation of ethical behavior into business practices presents many challenges due to the intangible nature of ethics, the varying degrees to which ethical behavior is applied and expected in a given society, and cultural values in a society. Furthermore, CSR is an American-based concept, based on American cultural values and ethical assumptions. Therefore, this comparative study explores the differences in how the ethical components of CSR are communicated in the US and Germany and how cultural values affect the reporting of ethical activities of CSR. By applying a thematic analysis of the top 10 US and German companies’ CSR reports, it was discovered that American companies take a more explicit approach to the communication of ethical components of CSR, focusing on codes of ethics to guide behavior and extensive philanthropic activities to demonstrate ethical responsibility. Germans take a more implicit approach to communicating their ethical behavior and participate in less philanthropic activity. However, the German companies emphasize the obligation of business in society as an equal partner, whereas the US companies stress the importance of corporate social responsibility for the benefit of the company, reflecting a value of individualism in US society.