I find that the model (even the Culture factor) presumes that the person is aware that the behaviour in question is malpractise. But awareness depends on the type and degree of the behaviour. So, keeping with the C-theme, maybe Consciousness could be a relevant factor as well.

Yes, that is sort of a boundary condition to this version of the model. The term CLARITY may be used to describe differences in how aware the actor is of the unethical dimension of the behaviors in question. If we want to avoid the ambiguous term CULTURE, maybe CUSTOM works better.