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Thomas Pogge’s notion of moral loopholes serves to provide support for two claims: first, that the ethical code of the global economic order contains moral loopholes that allow participants in special social arrangements to reduce their obligations to those outside the social arrangement, which leads to morally objectionable actions for which no party feels responsible and that are also counterproductive to the overall objective of the economic system; and, second, that these moral loopholes are more likely to exist as our economic order becomes more global. Finally, it will be shown that attempts to rectify the situation with voluntary corporate codes of conduct are inadequate. The argument proceeds through analysis of one case study, concerning action by the executive of the Cerrejón mining operation at La Guajira Penisular, Colombia.