This paper examines the role of culture in the development of higher education institution (HEI) policy on widening participation. The study involved documentary research and interviews with senior and middle managers. It suggests that a culture of widening participation is often not embedded throughout institutions. Therefore, widening participation policy formulated at the senior management level is likely to be reinterpreted, revised--and in many cases even undermined or ignored--as it migrates down the organisational hierarchy. The paper contends that senior management take insufficient account of the cultural complexity of HEIs. As a result, there is too much emphasis on institutional (or "meso") level policy-making and a top-down approach. The paper argues that more attention should be given to generating widening participation policy at the micro level within universities and colleges of higher education.