Ethics

Corporate Governance Services

Suggested Guidelines for Writing a Code of Ethics/Conduct

Writing a Code of Ethics/Conduct

Companies that follow both the letter and the spirit of the law by taking a “value-based” approach to ethics and compliance may have a distinct advantage in the marketplace. Give the average employee a legalistic “thou shall not….” code, and a negative response is almost guaranteed. Give employees a document that states clearly and concisely the company’s expectations, outlines acceptable behaviors, and presents viable options for asking questions and voicing concerns, and the likelihood is much greater that they will meet those expectations and exhibit the desired behaviors. Make the contents of the code equally applicable to everyone in the organization—at all levels—and you have a key ingredient for a code that becomes cultural, with all of the benefits.

Code Basics

There is no standard wording for a code of ethics/conduct. Each organization should develop one to suit the needs of its personnel in defining expected behaviors and in addressing the risks, challenges, and customs in the countries in which it operates, as well as to fit their specific industry and situation. However, there are some basic points to keep in mind when creating or modifying a code. • The code language should be simple, concise, and readily understood by all employees. • The code should not be legalistic—written as “thou shall not”— but rather state expected behaviors. • The code should apply to all employees and be global in scope. If the code addresses financial risk and applies to all personnel, there may be no need for a separate financial code of ethics. • The code should be written, reviewed, and edited by a multidisciplinary team in order to be reasonably confident that it is consistent with other corporate communications and policies, addresses relevant risk areas, has buy-in across the organization, and represents the organization’s culture. Consider...